Earlier this month the Centers for Medicare & Medicaid Services issued its fifth set of proposed Medicaid federal upper limits (FULs) for generic drug reimbursement, but it’s no better than its four predecessors for patients and their community pharmacists, NCPA recently wrote to the agency.
NCPA’s analysis of the list found “serious shortcomings that would result in devastating economic consequences for small business community pharmacies that serve Medicaid patients.” The NCPA letter to CMS also points out that, for hundreds of common, multi-source generic drugs, the latest proposed caps, or FULs, are lower than independent pharmacies’ current, market-based acquisition costs.
“If this set of FULs is implemented, it could result in the loss of access to community pharmacies for Medicaid patients,” NCPA wrote. “This could result in negative health consequences and sharply increased Medicaid costs for other health interventions if Medicaid patients cannot obtain their prescription medications.”
The letter renews NCPA’s call for CMS to refrain from publishing additional FULs or from implementing them until a final rule can be put in place governing how manufacturers calculate their average manufacturer prices (AMPs), on which the FULs are based. In addition, NCPA reiterated a number of points made in its previous letters to CMS, including the fact that most states set reimbursement below the federal reimbursement limits (worsening the impact of inadequate FULs)
Click here to read a copy of NCPA’s letter.