APhA, pharmacists, and other pharmacy organizations are staunch in our support for many of the provisions in CMS’s Contract Year 2015 Policy and Technical Changes to the Medicare Advantage and the Medicare Prescription Drug Benefit Programs Proposed Rule released on January 10, which makes changes to the Medicare Part C and Part D programs. The proposed rule contains important Part D reforms, including greatly expanded medication therapy management (MTM) eligibility, an “any willing pharmacy” provision designed to allow pharmacies willing to accept a plan’s terms and conditions to participate in currently restrictive networks, and changes that place mail-service pharmacies and community pharmacies on an even playing field. While we do not support every aspect of the rule, we believe that each provision of this rule should be considered on its own merit.

Last week, the Healthcare Leadership Council sent a letter to CMS requesting that CMS withdraw the proposed rule. More than 200 disparate organizations—including PBMs, plans, and other industry organizations—signed the letter.  These organizations don’t share the same reasons for opposing the rule. They are united solely by their opposition to various, and, in many cases, not even the same, provisions of the Rule.

The approach recommended by the Healthcare Leadership Council is a shortcut—an attempt to head off meaningful reform by attempting to circumvent the regulatory process. The Healthcare Leadership Council’s letter stated that the proposed rule “represents unnecessary changes to programs that are already extraordinarily effective in containing costs and, most importantly, will severely impede beneficiaries’ access to affordable health plans and medicines.” We maintain that proposed provisions regarding MTM, “any willing pharmacy”, and mail-service provisions in the proposed rule would do precisely the opposite. These changes would improve patient outcomes and would increase patient access to and choice of pharmacy services in a cost-effective manner.

APhA and other pharmacy organizations will continue to advocate for patient health and patient freedom of choice, and therefore for regulations that expand MTM and a patient’s ability to receive care at the pharmacy of his or her choice. These provisions should not be rescinded simply because some organizations take issue with other provisions of the proposed rule. A couple of hundred signatories on a letter are impressive, but CMS had already received 1,756 individual comments on the rule by this morning, well before the comment due date of March 7, 2014. I think it’s fair to say that many of those comments could be from individuals and organizations that support the rule.

Change is hard and reform is almost always controversial, but it is necessary to improve the Part D program. All voices should be heard. We strongly encourage you to submit your own letter of support for the proposed rule by March 7, 2014. Learn more and see a sample letter.