AMCP Statement on CMS' 2015 Draft Call Letter

"CMS' Call Letter offers a mixed bag," AMCP CEO Edith Rosato said. "AMCP commends CMS for some proposed changes, but raises serious questions about others." 

For Immediate Release

Alexandria, Va., February 25, 2014 — The Academy of Managed Care Pharmacy (AMCP) today released the following statement by CEO Edith A. Rosato, RPh, IOM commenting on the Centers for Medicare and Medicaid Services' recently released CY 2015 draft Call Letter for Medicare Parts C and D, as follows:
"The Academy is concerned that CMS' Call Letter for 2015 offers a mixed bag: AMCP commends CMS for some proposed changes, but raises serious questions about others." 
"CMS appropriately calls for a study on preferred cost sharing. CMS leaves open the possibility, however, that the entire system of preferred networks could be abandoned before all the facts are in, based on provisions in the Part D proposed rule to upend the current preferred network infrastructure. AMCP cautions CMS to include enough health plans with preferred networks in the study to ensure a fair and accurate result. AMCP also urges CMS to complete its study before finalizing the preferred network provisions in the proposed rule." 
"We believe CMS should refrain from making major changes to Medicare's medication therapy management (MTM) program, until plans have full capability to conduct targeted medication reviews (TMRs) and comprehensive medication reviews (CMR) using a health information technology (HIT) infrastructure. CMS' own analysis in the call letter finds that the program lacks this infrastructure. AMCP has long advocated for HIT standards for MTM and is working with other industry stakeholders in this area. With CMS now contemplating a government-directed solution, it's imperative that the industry collaborate and develop these standards." 
"We're pleased that CMS agrees with AMCP that additional studies of CMR and TMR completion are needed. But AMCP is very concerned that CMS' current study outlined in the call letter included only 25 health plans, which is not an adequate or representative sample. The issues presented in the sample also reflect that TMR and CMR outreach and reporting to beneficiaries, prescribers, and CMS could be improved by an HIT standard that streamlines dissemination of information." 
"AMCP supports CMS' efforts to allow health plans flexibility to provide MTM to expanded patient populations and patients targeted for additional opioid monitoring and include this information in bid amounts. AMCP supports flexibility in MTM; however, if CMS' Medicare Part D draft rule to expand MTM is implemented, it will become more difficult for plans to provide reasonable bid amounts that include the expanded MTM population." 
"Finally, we applaud CMS' efforts to allow plans to implement utilization management for opioids. Prescription drug abuse is a public health crisis, and AMCP supports CMS' efforts to work with plans to ensure appropriate opioid utilization. Efforts between plans and CMS should be a collaborative effort that is not punitive in nature, but rather, helps to streamline processes to ensure appropriate opioid utilization." 
About AMCP  
The Academy of Managed Care Pharmacy is a national professional association of pharmacists and other health care practitioners who serve society by the application of sound medication management principles and strategies to improve health care for all. The Academy's nearly 7,000 members develop and provide a diversified range of clinical, educational and business management services and strategies on behalf of the more than 200 million Americans covered by a managed care pharmacy benefit. It is celebrating its 25th anniversary in 2013. More news and information about the Academy can be found at
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