Independent Pharmacy Owners Have Spoken: Recent Pharmacy Surveys Identify Top Policy Priorities and Frier Levitt Has Practical Solutions
The National Community Pharmacy Association (NCPA) recently released the results of a survey of its independent pharmacy owners to identify their top policy priorities for 2018. According to the survey, independent pharmacies ranked four key desires: (1) elimination of retroactive pharmacy DIR fees; (2) ensuring MAC transparency to address delays in payment rate updates and appeals processes; (3) obtaining reasonable Medicaid pharmacy reimbursement; and (4) gaining access to Medicare Part D preferred networks through the any willing provider law. Sadly, these priorities are not new – they are themes that have consistently presented challenges to independent pharmacy owners.
Fortunately, however, solutions do exist and are available to independent pharmacy owners if they take action and assert their rights. Frier Levitt has developed several flat fee services offered to independent pharmacy owners, aimed at helping them to address and remediate these challenges. Each flat fee service is designed to provide direct value to pharmacies, while keeping costs low and predictable.
- DIR Analysis Flat Fee – For a Flat Fee of $500, Frier Levitt will conduct a review of your existing DIR Fee arrangements and counsel you on different options and avenues available to you, based on your pharmacy’s unique circumstances. This may include strategies to reduce the extent of DIR fees assessed against your pharmacy, or a roadmap to challenging specific PBM conduct. Moreover, once we’ve reviewed your DIR fees and options with you, we can often undertake the next steps at reduced flat fee rates as well, providing you further predictability and cost savings in pursuing one or more of these options.
- MAC Analysis Flat Fee – For a Flat Fee of $750, Frier Levitt will conduct a review of the impact of PBM MAC prices on your pharmacy’s business, and will provide an analysis of your State’s MAC appeal laws. Included within the Flat Fee will be a framework for appealing unreasonable MAC prices, as well as a variety of options to further challenge unfair MAC pricing within your State.
- NADAC Pricing Challenge Alternative Fee Arrangement – For a Flat Fee of $3,500, Frier Levitt will review your pharmacy’s data comparing drug acquisition and reimbursement rates for your state’s Medicaid Program. We would then research applicable state Medicaid NADAC pricing policies and applicable state laws, and develop potential causes of action against the applicable state Medicaid agency or other entities to challenge NADAC pricing. Finally, we would provide a memorandum regarding action items and options to execute on our plan to challenge NADAC pricing under your state’s laws.
- Medicare Part D Network Access Alternative Fee Arrangements – Exclusions from Medicare Part D networks can have real impact on a pharmacy’s ability to maintain relationships with existing patients and prescribers, and to remain competitive. Frier Levitt has ample experience in assisting pharmacies gain access to Medicare Part D networks, and can assist pharmacies seeking admission for a low up front flat fee, with a success fee in the event we are successful. This Flat Fee payment shall cover the drafting of a demand letter to the Pharmacy Benefits Manager/Part D Plan Sponsor and one (1) substantive conference call with the PBM to discuss the pharmacy’s demand to be admitted into the PBM’s pharmacy networks. The Flat Fee for this letter would be $4,500 for the first Medicare Part D Network, and $1,750 for each Medicare Part D Network thereafter. If we were successful in causing the PBM to allow the pharmacy to fill for claims processed or beneficiaries covered under said network, we would be entitled to a success fee of $10,000 per network.
If you are interested in one or more of these Flat Fees, contact Frier Levitt today.