With prescription drug shortages and pharmacy compounding hot topics, NCPA recently weighed in with Food and Drug Administration (FDA) officials on both fronts, in hopes of preserving patient access to essential medications from their independent community pharmacist.
In response to FDA’s comment period regarding its Drug Shortages Task Force and Strategic Plan, NCPA raised three key points.
First, NCPA “strongly encourages FDA to address effectively the issue of drug shortages and in doing so preserve the role of compounding pharmacies in providing critical patient access to these medications.” Compounding pharmacies can play a vital role in alleviating drug shortages. For example, this past flu season was accompanied by increased demand for Tamiflu oral suspension. FDA placed the product on its current drug shortages index and reminded all health care professionals of the FDA-approved instructions for emergency compounding.
Second, Medicare and Medicaid policies should allow for pharmacies to be reimbursed fairly for critical access prescription drugs that are subject to a shortage. That’s likely a familiar theme to the many community pharmacists who have cited inadequate—even below cost—payment levels that are updated weeks or months after costs spike (and without retroactive compensation).
In the case of Medicaid, NCPA’s comments note that, “when a drug becomes a critical access drug the acquisition cost may immediately skyrocket, but the [Medicaid reimbursement benchmarks] will not adjust for those changes until months later. Therefore, pharmacies end up purchasing critical access drugs at suddenly high prices, while the reimbursement remains the same and fails to adjust. We would encourage the task force to consider recommendations such as a suspension on limiting reimbursement in Medicaid to the FUL for any critical access drug and would require the Health and Human Services (HHS) Secretary to establish a new benchmark for reimbursement for those drugs, which reflects the changing costs of those drugs.”
When it comes to Medicare’s Part D prescription drug benefit, NCPA’s comments call for “the requirement of more frequent updates by Part D plans” to reflect rising drug costs, particularly for critical access medications, and more government oversight of the process.
Read NCPA’s full comments to FDA here.