Here at the Thriving Pharmacist, we often write about where we believe the practice of pharmacy should going, and given the feedback we receive, there are more than a few pharmacists that agree with our direction. In a nutshell, we believe that pharmacists and pharmacies should be documenting patient care, evaluating outcomes of therapy and working with patients and prescribers to optimize medication use. There is evidence already available (some discussed on this blog previously) that pharmacists, when used in this manner, can benefit the healthcare system in significant and meaningful ways. This includes financial benefits to the healthcare systems, with significant savings realized in total health spend.
But healthcare today is very fragmented, and this creates the potential for inefficiency. The companies paid to manage the prescription benefit (Pharmacy Benefit Managers or PBMs) often have no stake in the total health spend. The primary mechanisms used by the benefit managers to save the healthcare systems money are downward pressure on the cost of medications and (more recently) DIR fees taken from member pharmacies and shifted back to the health plan. The health plans appear to be mostly unaware that pharmacists, used properly, can positively impact their bottom line in other ways.
This myopic doctrine manifested when Congress handed the Medicare Drug Benefit (Medicare Part D) over to the PBMs to run. The PBMs are only responsible for drug costs. The accountability for total health spend falls to Medicare Part B, so any programs under Medicare Part D that leverage pharmacists to increase medication compliance and improve medication related outcomes come at the expense of the PBMs with no return on the PBM investment. It comes as no surprise, then, that Medicare Part D MTM programs have been mostly non-starters, with very few patients eligible, and plans using internal resources instead of the patient’s own pharmacist to implement them. The PBMs appear to view these programs as added expense without a return on their investment.
This fragmentation is allowing the tail to wag the dog. The Medicare Part D benefit has become a “success” from the prospective of congress, with the savings the PBMs have shown. These savings have largely come at the expense of the bottom lines of the actual providers in the trenches, though. One only has to look as far as Medicare’s own reports to see that the PBM industry is doing quite well, quite possibly making as much money managing the benefit (charging a spread on each prescription) as the pharmacies actually caring for the patients. The recognition by the government that the current problem is a success further propagates the currently popular PBM strategies that have forced down the price paid to pharmacies for medications without looking at the bigger picture: medications (when used correctly) are an incredibly cost-effective way to save total healthcare costs. It is not always the least expensive medication that is going to save the system the most money in the long run, but the tail continues to argue cheap is better, and the dog doesn’t seem to be complaining.
The solution for health care, however, is just waiting to make it through congress. By giving provider status (with Medicare) to pharmacists, the real benefits of pharmacy can grow beyond Medicare Part D’s emphasis on cheap drug product. Paying pharmacists to make interventions that ultimately save the provider (Medicare part A and B) in total health spend makes significantly more sense than the current model focusing almost exclusively on drug cost. In effect, provider status for pharmacists will ultimately use pharmacists where they can save the most for the system.
Today’s assignment is for every pharmacist to have an encounter with their elected officials in Washington DC. Refer them to some of the examples discussed previously on this blog (things like the Army’s own reports, and studies looking at savings by improving compliance and other examples) where pharmacists can save the payor money. Help them understand that pharmacists are an important asset to help Medicare survive. Make your encounters count. Get help them understand the importance of Medicare acknowledged provider status to pharmacists. If they have not already signed on in support of the current bill, encourage them to do so. Help stop the tail from wagging the dog.
The previous analysis of narrow network DIR fees generated significant attention, and several people were interested in more details about the medications that were severely underwater.
Notes
It is important to note that the 10 drugs listed below represent 10 drugs our pharmacy dispensed during a 3 month period to patients using one specific narrow network with a DIR fee. It is unlikely that these 10 medications are the only severely underwater products, but without a broader sample of claims data, this is unknown. Below I have established an estimate of best current (July 2015) available price using a variety of alternative generic wholesaler vendors for the drugs. Because the analysis was initiated retrospectively, determining an actual historical best available price was not feasible. For each drug, I have calculated a ratio of the approximate best net acquisition cost (after DIR fees were applied) to the product reimbursement. For example, if the best acquisition for drug X is $10 / tablet and the net payment after DIR is $2 /tablet, the ratio would be 5:1. These ratios are rounded, as contracts prevent a pharmacy from disclosing actual acquisition costs of items.
This medication has long been subject to underwater issues and represented 3 claims during the analysis period. Based on acquisition cost (before any rebates are applied) our pharmacy system shows losses of hundreds of dollars for this high dollar generic. Unfortunately, because this is a Schedule II (C-II) controlled substance, buying from other sources is more challenging for a variety of reasons. It is also possible that some pharmacies could have better contracts on this medication than others. Based on our best acquisition price (after rebates): Ratio 4:1
Brimonidine 0.15% Ophthalmic Solution (10 ml)
There were only two prescriptions for this in our 3 month data set, but each one resulted in more than a $100 loss. A check of alternate generic wholesalers did not reveal any currently available product below our net (after rebate) acquisition cost. It should be noted that the other strength of this medication (Briminodine 0.2%) is significantly less expensive, possibly alluding to the basis of the ultra-low reimbursement. Ratio 6:1
Cefdinir 300 mg Capsules
This drug represented only one claim in the data set. Currently, there is a product available at a price significantly less than we paid back in March, 2015, but even with this lower priced product available today, the claim would remain underwater. It would take an acquisition cost of about $0.50 per capsule to break even. Ratio of 1.2:1
Chlorpromazine 50 mg and 100 mg Tablets
These two strengths of the drug represented ten claims during get test period and resulted in a loss of more than $2,800 by themselves. The product saw price a significant price increases back in September of 2014: the price increased by over 300%. The price has been falling slowly over the last couple of months, but remained steady during the analysis period. Reimbursement, after DIR fees were removed, were around $1/tablet (50 mg strength) and $1.40/tablet (100 mg strength). It is worth observing that the current reimbursement is in line with the pre-increase acquisition costs of the medication. Even given the best price today, losses for this drug would still be very significant. Ratio 3:1
Divalproex ER 250 and 500 mg Tablets
Our pharmacy serves many seizure patients, and because of this, we have a policy to minimize unnecessary changes in manufacturers for seizure medications that might result in the deterioration of seizure control of our patients. Reimbursement considerations make this infinitely more difficult, as the third party payor doesn’t have any stake in ER visits and hospitalization costs. This being said, our current divalproex ER products have remained stable for quite some time and have (thankfully) been the least expensive option available to us. Looking around for the best available price today (without respect to changing generic manufacturers) does alleviate some of the losses, but does not move the profit indicator out of the red. Ratio 3:1
Divalproex Sprinkle 125 mg
This product is an immediate release variant, and changing manufacturers is less of an issue. Looking at the best available price today does show one product (from a company I have never seen before) priced around $0.04/capsule. If one were inclined to trust this product (and if it was even available at this price in the first quarter of this year) one could have made a small profit on the product after the DIR fees. Therefore, this product was ignored for the purpose of ratio calculations. Ratio 5:1
Donepezil 23 mg Tablets
There was only one prescription for this medication in the data set, but based on our best price at the time, we lost over $270. Back when the prescription was filled, only one product was available at a cost of more than $10/tablet. Today, with the a product now available for closer to $3/tablet, the loss would still not be eliminated. Reimbursement is closer to $1/tablet. Ratio was: 10:1 (would be 3:1 today)
Methylphenidate ER 18 mg Tablets (Generic Concerta 18 mg)
Back in November of 2014, the FDA determined that two of the three available generic versions of Concerta were did not meet FDA Orange Book guidelines for rate and extent of absorption, and therefore could not be considered generically equivalent (AB rated). This meant the product effectively became single source. The reimbursement, after DIR fees are accounted, hovers around the acquisition cost of the non-substitutable, less expensive product. Ratio: 5:1
Equity in Pricing
Note that contracts prevent pharmacies from disclosing their actual acquisition costs for products. It is safe to assume that larger groups of pharmacies (chains and large independent buying groups) may receive better pricing than smaller groups. By participating in a large buying group, independent pharmacies should be able to receive prices similar to large chain pharmacies, and this is mostly true. There are reports, however, of a few medications that are deeply discounted to individual groups. This is sometimes referred to as corporate contracted rates for a drug. Some of the drugs in the analysis above may be subject to these contracts, and the pharmacies receiving that special pricing may not actually lose any money on the prescriptions.
It is likely that the PBM industry leverages these deeply discounted contracts in their MAC price calculations, and this may explain some of the severely underwater reimbursements seen by pharmacies not receiving this special rate. The “black box” nature of MAC prices (the PBM considers their MAC pricing formula proprietary and a trade secret) makes it impossible to determine the reason behind underwater prices. DIR fees simply make the situation worse. Requests to the PBM to update the MAC price for a drug to account for real-world acquisition price often receive a “no adjustment required, product available at a lower price. MAC Price justified” type response. This is of little consolation to the pharmacy that cannot purchase the product at a rate even close to a break-even price. There is no “request to review” a DIR fee.
There are, however, reports that some wholesale drug companies and buying groups are looking at ways to help pharmacies (especially independent pharmacies). Currently, the wholesale drug companies and buying groups do not have skin in the game. There is talk, however, of these two groups offering pharmacies a form of price protection from severely underwater products in the form of rebates, thereby offsetting some of the losses. Without some for of safety net, pharmacists have to make some difficult choices in what to stock and not stock in their stores.
Last week, one of the Medicare Part D plans using Mirixa for Medication Therapy Management (MTM) “dropped” a new batch of “Star Measure” alerts to our pharmacy. These have been previously discussed here on this blog.
This “drop” was not unlike previous iterations our pharmacy has seen; the patients highlighted for possible compliance issues were exclusively patients residing in group homes. Each of the patients have staff working with them to ensure that they take their medications, and all of their medications are in compliance packaging (either OPUS cassettes or other systems to enable the staff to make sure that all doses are given). Every time the patient misses a dose, the staff report the incident to us, and we document the pertinent details in our clinical documentation system (PharmClin). Needless to say, if a patient is severely non-compliant, we would know quickly (because we would be receiving calls several times a week).
If it is not obvious by now, every one of these Star Measures cases were a false positive. Each patient was, and continues to be, nearly 100% compliant (as a percentage of days covered or PDC). So why were these cases brought to our attention? The answer relates workflow.
The workflow required to handle the large number of prescriptions dispensed on the same day each month to a large group home population requires a fairly involved process that is mostly automated by our pharmacy dispensing system. Even with this automation, billing may be delayed by up to 10 days for some prescriptions*. Keep in mind that it is the billing that is delayed, not the delivery of the medications.
Discussion
What is surprising is how quickly the plan and Mirixa identified what they perceived as compliance issues. We received the notices just short of 2 weeks after the due date of the prescriptions. That is just short of amazing, and some of our patients would consider this type of “short leash” offensive (and even an invasion of their privacy) if they were aware of how tightly the benefit manager is tracking them.
In this case, the delay in billing within our workflow resulted in sixteen “opportunities” to document and collect some “clinical” reimbursement from the program. Each of these cases is an opportunity to earn $12 by responding to the case (without respect to outcome). There are, however, two caveats about this program that should be noted.
Each of these $12 interventions will be withheld from the performance incentive paid to the pharmacy (by the plan) at the end of the year (assuming we exceed drug specific patient compliance metrics). In other words, each $12 is effectively just an “early” performance payment.
The Mirixa system for addressing these issues is time-consuming. If a pharmacist completes the intervention completely (updating each medication and answering all prompts), it takes a minimum of fifteen minutes to complete the intervention (not counting any patient contact time). This is not cost effective, as it does not come close to covering the time spent by the pharmacist.
The Pearl
These Star Measure interventions (or SSI Performance Network Program) are a much more focused intervention than a complete Medication Therapy Management Program encounter (MTMP). The reimbursement level (at just $12 per incident) reinforces this statement. To handle these interventions efficiently, make a call to the patient (this does not merit a face-to-face) and ask some open-ended questions. Patients can become defensive when approached about compliance, so it is wise to deflect this initially, noting that there are many possible reasons for this (like physician samples, dose changes, side effects etc) and let the patient fill in the rest of the story. For example:
We have noticed that your refills of lisinopril have not been as frequent as we expected. Often, changes are made by the prescriber, and the pharmacy is the last to know. How are you currently taking the medication? What difficulties, if any, are you having with the medication?
At $12 per intervention, break-even time (at a pharmacist salary of $50/hr) for this case is 14 minutes, so this phone call has to be efficient. You need only to establish if there is a real problem and a brief explanation. The phone call might take three to five minutes to complete.
Data entry must also has to be efficient. A tip for pharmacists working this type of problem in Mirixa: do not spend time updating the medication profile. It is not obvious, but leaving this portion of the intervention unfinished will not prevent (at least for now) the intervention from being completed. By omitting this information (and only addressing the fields that relate to the compliance issue at hand), a pharmacist should be able to complete the Star Measure intervention (call and data entry) in less than 10 minutes. This is much more in line with the actual reimbursement being offered.
Footnotes
* July 2015, with the observed holiday of Friday July 3rd, is a worst case scenario of delayed billing.
Medication synchronization is a popular service offered by more and more pharmacies. The premise is two fold. One: create a convenience for your patients such that they only have to stop by the pharmacy once to get all of them medications. Two: allow the pharmacy to optimize its own workflow, as refills are now able to be scheduled like an appointment. This makes upcoming work load more predictable. The theory behind this would seem simple enough. In practice, however, synchronization is a little more challenging. Synchronization is more than just an auto-refill feature (offered by some pharmacy management systems). It involves actively validating all medications and quantities each sync period. This means a call to the patient and quick calculations of what the patient will need for the next sync cycle.
Medication synchronization at the very basic level is just a paperwork exercise. Simplify My Meds and other programs offer a paper based workflow to plan and execute synchronization. In our practice, after starting with a simple paper based system, it quickly became obvious that the operation could be very time intensive to the pharmacy staff. We realized that the process needed to be automated if we were going to move from a few dozen patients to a few hundred or even thousands of patients. There are a variety of vendors that now offer software services for synchronization. These allow the pharmacy staff to schedule and update each sync cycle. These software packages, however, are no better than the data that they extract from the pharmacy management system, and we have seen many problems arise with inaccurate or incomplete data being pulled by the vendor. This has resulted in our staff spending extra time verifying the data before synchronization can progress. The automated systems have the potential to save time, but until the data can be presumed accurate, we are still not optimizing our staff.
The workflow of synchronization ends on the prescription counter. On a given week, we are able to schedule the filling of sync patients during less busy times of the day because we know what prescriptions need to be filled several days in advance. Even with a reasonable barometer of pending workflow, we still end up congested on our prescription counter. The process could benefit from optimization. To do this, we need to speed our fill and check cycle, and robotics are an effective vehicle to accomplish both goals.
Rosie the Robot
Awhile back I wrote about our SuperSync program which leverages our Parata Pass robotic “unit dose” packaging robot. Our Pass-208 was named Phyllis (a play on the verb fill) was originally purchased to handle nursing home business. We have more and more patients that are electing to receive their retail medications using this method, and this has helped with our congestion issues. But as fast as the SuperSync patient base is growing, our sync program overall is growing faster. We had to make a decision: Phyllis is going to be a big sister. In the coming weeks, Max (a Parata Max) will be joining the family.
The symbiotic relationship between a robotic prescription filling robot and a med synchronization program is natural. The combination is so natural that currently Parata is offering a free year of the PrescribeWellness medication synchronization software when one purchases the machine. Using Max, our pharmacy can be actively filling med sync patients overnight, and the pharmacy tech or pharmacist can check the medications and get them to the shelf for pickup first thing in the morning.
Workflow Modifications
One of the more interesting discussions we had with respect to our workflow (working toward the upcoming installation of the robot) centered around our pharmacist’s CMM (Continuous Medication Management) program. Our normal workflow is:
[Intake] -> Data Entry -> Filling -> Final Verification* -> CMM -> Will Call
*In our practice, we are using a New Practice Model, which allows the Final Verification step for routine refills to be completed by a certified technician who has received extra training.
The CMM component for all prescriptions (regardless of the person doing final verification) must be done by the pharmacist.
In our discussions, our Medication Sync program starts with the pharmacist doing a reconciliation of the patient medications each sync period. Our workflow, therefore, could be modified to move the CMM to the beginning of the model along with the reconciliation done by the pharmacist:
CMM -> Data Entry -> Filling (overnight by robot) -> Final Verification* ->Will Call
This further decreases congestion on our counter as a significant number of prescriptions can be filled overnight and checked by a technician and moved directly to will call. The only issues are
how to segregate new prescriptions from refills at the robot level and
How to segregate Sync refills from non-sync refills
Both of these issues can probably be solved by minor modification to our clinical software system (PharmClin), which is used at the point of final verification.
Closing
While the OnePass packaging option (the Parata Pass 208) is gaining in popularity, we are also growing our regular sync customer base by leaps and bounds. Our goal is to have 30% of or customers on a sync program within the next 12 months. We have enrolled 150 new patients in the last couple of months and currently are at more than 250 sync participants. This change in our workload has lead to some issues with congestion on our prescription counter. Leveraging robotics in our workflow is one way we hope to enhance our workflow. The main goal, as always, is to be sure our pharmacists are free on the counter to perform CMM on every patient picking up prescriptions, making every encounter with the patient count.
I have heard a lot different angles (mostly negative) about certain narrow network Medicare Part D plans. These plans are somewhat exclusive, and many chains and independents were not offered, or declined contracts due to the very aggressive reimbursement offered. Some aspects of the overly complicated DIR (Direct and Indirect Renumeration) fees this plan leverages have been previously discussed on this blog here.
This specific plan is so polarizing in pharmacy circles that some pharmaceutical wholesalers even have come into our store bragging that their member pharmacies (represented by their PSAO – Pharmacy Services Administrative Organization) declined these contracts, essentially implying that stores participating in the narrow “Preferred” network were worse off having access to these lives. This is completely opposite of our feelings that access to lives is very important.
This specific plan reports DIR fees in a way that makes it very difficult to see bottom line reimbursement; the plan reports DIR fees retroactively, attaching last months DIR fees to unrelated claims on the current pharmacy remittance information. Up until recently, when our PSAO, AccessHealth, began matching the DIR fees associated with each prescription for us, analysis of profit and loss was almost impossible. With this report, pharmacies can take a closer look at how this contract impacts their bottom line.
Analysis
AccessHealth (and presumably other PSAOs that did not sign this contract) analyzed the potential profitability of this contract before deciding to sign (or not sign). The fact that AccessHealth did sign the contract indicated that it was their belief that member pharmacies would benefit overall from this contract, fully understanding the “aggressive” reimbursement and DIR fees would make it important that pharmacies maximize this access to lives by leveraging other revenue streams to make up for the lower prescription revenue. Using the data recently provided to our pharmacy, 872 claims (January thru March) for this plan were analyzed for their impact on our pharmacy. The question being addressed is this: is participation in this narrow network sustainable for a medium to large independent pharmacy.
General Statistics:
This plan represented 872 claims (Jan-March), each with an associated DIR fee
The total adjudicated amount for these claims was $66,855 before DIR fees
DIR fees were withheld from 568 of these claims totaling $14,694
“Negative” DIR fees (money returned to the pharmacy) were paid for 317 claims, totaling $2,020
Looking at these numbers, it is interesting to note that there were over 300 generic drug claims that were reimbursed at a MAC (Maximum Allowable Cost) that was BELOW the DIR’s contracted rate. This effectively gave money back to the pharmacy in the form of a NEGATIVE DIR. This “feature” of the DIR actually may help protect the pharmacy from some overly aggressive MAC prices for certain drugs. That being said, the withheld DIRs dominated these returned DIRs. The net DIR total for this plan in our pharmacy bottom line is about $4,000 per month returned to the plans in exchange for participation in the network.
Watching the Bottom Line (Profit or Loss)
Calculating profit or loss on a prescription is normally not that difficult, and it can be usually be done at the point of sale before the prescription leaves the pharmacy. The addition of DIR fees complicates this tremendously, because these DIR fees are unknown to the pharmacy until well after remittance arrives. The pharmacy may also receive a rebate on some generic products (based on the pharmacy’s purchase volume), though the pharmacy can usually estimate the rebate before it is actually received. Not every generic product, however, may be rebatable.
Once the pharmacy knows both the DIR and the rebate, a profit or loss can be calculated for each prescription. When a prescription is reimbursed by the PBM for less than it costs the pharmacy to purchase the product, is often described as “underwater.” For the 872 claims above, more than 90% of the prescriptions were generic. Other descriptive statistics for the claims include:
72 claims (8%) were “underwater” before DIR fees were applied to the claims
304 claims (35%) were “underwater” after DIR fees were applied
DIR fees averaged an additional 19% discount from the adjudicated claim amount
To a pharmacy owner, any underwater claims are unacceptable, and the large number of underwater claims for this plan is very discouraging finding. The more important statistic, however, is the gross profit or loss for these prescriptions, and applying the rebates should offset losses and have a positive impact the pharmacy bottom line. If the estimations done by the PSAO before signing the contract adequately reflected actual claims finding, the total profit for these claims should be positive.
Before generic rebates were applied to the above claims (but after the DIR fees were withheld), the pharmacy lost $6,552 on these 872 prescriptions. The amount pharmacy receives in generic rebates is variable (dependent both on the pharmacy’s purchase volume and the other contractual obligations), and for this reason, a range of rebate rates for generic drugs was calculated. For our buying group, rebates are calculated as a percentage of invoice price for qualifying items. This type of rebate application may not be representative for other buying groups outside the one which our pharmacies maintain membership.
For the purposes of this analysis, generic rebate rates of 20%, 25%, 30% and 35% were used. These calculations assume that every generic drug dispensed was eligible for a rebate. There are cases, however, where the least expensive drug (after accounting for rebates) is not a rebatable product. The assumption that all generic drugs were subject to a rebate may, thereby, overstate the effects of rebates on the pharmacy’s bottom line. The calculations below are then only estimates that should be representative of ballpark profit or loss on these prescriptions.
In the table below, the first line (Rebate Total) represents to total rebates (based on the generic rebate rate in each column) that the generic drugs included in the 872 claims should have garnered the pharmacy. The second row is the Net Profit or Loss for the 872 prescriptions based on the rebates received, and the last row represents the average profit or loss per prescription for each of the 872 claims.
Several observations can be made from the table above. The most important, however, is that significant rebates are necessary in order to even break even on these prescriptions. While the disclosure of our generic rate is restricted by contractual agreement, I will state our pharmacy did not profit from these 873 prescriptions. I will further state that few if any independent pharmacies are likely to receive rebates that exceed 25-30%.
The distribution of the profitability of the claims is also enlightening. The chart below shows profit / loss ranges in $5 increments for all 873 prescriptions after subtracting the DIR fees but before rebates were applied. There are 78 prescriptions showing a loss of more than $25. On the other side of the histogram, only 48 prescriptions profited more than $25.
After applying rebates, the histogram shifts to the right somewhat, but a large number of severely underwater claims remain. The histogram below represents a 25% rebate level (one that is assumed to be fairly representative for most independent pharmacies). The loss for these 78 prescriptions was between $8,500 (using a 20% generic rebate) to $6412 (using a 35% generic rebate). That is an average of more than a$95 loss per prescription. These prescriptions are not underwater, they reside at the bottom of the Mariana Trench. The total profit for the “highly profitable” prescriptions (netting more than $25) was between $2,698 (using a 20% generic rebate) and $2,720 (using a 35% generic rebate). The discrepancy between the heavily underwater prescriptions and the highly profitable prescriptions represents most of the losses recognized by the pharmacy.
The number if “highly profitable” prescriptions do not change much after rebates, with the $20-25 bin increasing only by 1 prescription. The most noticeable change is the number of marginally underwater claims (those $10 to $15 underwater). The number of claims losing more than $25 does not change significantly because these claims are obscenely negative. The group of claims losing more than $25 deserves further examination. The graphic below further describes the left-most column in the two histograms above. This one column is broken into 6 groups: losing $25-50, losing $50-75, losing $75-100, losing $100 to 200, losing $200-500 and losing more than $500. A seventh group (the far right columns below) entitled losing less than $25 was added to house any prescriptions moving OUT of the trench. Blue bars represent losses before applying generic rebates, and the green bars represent losses after applying generic rebates.
The effect of rebates on these severely negative claims is small. The number claims losing more than $500 does not change after applying generic rebates. There is a small shift overall to the right in the other columns (indicating the positive effects of the rebates on these prescriptions), but only one prescription losing more than $25 before rebates actually “graduated” to a loss of less than $25. In other words, these claims are so far underwater based both on MAC and the DIR fee that even a very high 35% generic rebates cannot rescue them.
Looking closer at the drugs residing at the bottom of the Mariana Trench, several high dollar generic drugs appear to be the culprits. Looking at just one example, chlorpromazine, we see a claim for 186 tablets reimbursed at $595.18 minus a DIR fee of $336.67. Based on purchase price, the prescription started out underwater by over $1200. Because the purchase price is large, the rebate is proportional, resulting in $280 to $500 being returned to the pharmacy in the form of rebates. This still leaves the pharmacy between $650 and $900 underwater on ONE prescription. In fact, removing only 15 high priced generic medications from the analysis removes most of the 73 claims residing in “the trench”. If these claims were adjudicated in a fairly, the total of the claims would graduate from a net loss of $1791.65 to a net profit of $5161.23 (using a 25% generic rebate rate), which is a net profit of more than $6 per prescription. It would seem that the MAC and DIR calculations being used by this plan break down when generic drugs are very expensive.
Closing Remarks
It should be reiterated that the across the board application of rebates to all generics is an assumption, and that this will overestimate the effects rebates actually have on the bottom line of a pharmacy. That the bottom line is still red with this over-correction only emphasizes the need for reform.
Just breaking even on a prescription by the calculations above is not enough, either. No overhead costs were taken into consideration, and these are a significant part of a pharmacy’s expenses. It has been estimated that a pharmacy has to make an average of $9 to $12 per prescription to cover expenses (including a reasonable profit). The best case scenario (using a 35% rebate level) in the analysis above falls significantly short. This means that pharmacies need to find a way to make and additional $10-$12 for each prescription filled under this plan from OTHER services. Giving the patient a flu shot once a year, or selling the a bottle or two of over the counter vitamins 12 times a year is unlikely be enough to offset the significant losses these prescriptions currently bring to the pharmacy. I have always been a proponent of access to lives, but the above analysis shows that the pharmacy is paying the benefit manager a king’s ransom for the “privilege” of servicing these patients.
On a positive note, if the BPM were to correct their processing of a small number of medications (generic medications with very high acquisition costs) by correcting the MAC and /or and DIR components, the plan would draw considerably less ire from pharmacies and pharmacists. The concepts of MAC pricing and DIRs, if applied in a fair manner for all medications, might even be considered reasonable. The draconian manner in which it is currently being applied, however, creates significant problems. Pharmacies could address this problem by refusing to stock a small number of medications that are responsible for a majority of the losses being seen. It would be unfortunate if a shortsighted PBM’s policies resulted in a widespread loss of accessibility of certain medications to patients.
The ball is now back in the contracting organization (PSAO) to work with the PBM to address the problems outlined above. The current MAC and DIR calculation formulas appear to be broken for certain high cost generics, and this needs to be addressed immediately. Even if a pharmacy is not contracted with this specific plan, these tactics are becoming commonplace in the industry. Pharmacies need to be working closely with their contracting organizations to reform these tactics now. Normally I end each blog post by telling pharmacists everywhere to make every encounter with their patients count (a phrase so important that we even registered it as a trademark). Today I am asking every pharmacist to have an “encounter” with their PSAO. Make it count. Pharmacy is a great profession. Pharmacists bring significant value to healthcare. Reimbursement reform should be a goal every pharmacist works toward.
As a pharmacy owner, I tend to visit pharmacies (especially independent pharmacies) when I travel. There is a lot of history to be seen in some stores, and even new ideas to be hatched. While visiting an independent pharmacy in Little Havana (Miami Fl) that was right out of the 1950’s, it occurred to me that the front end (non-prescription area) of a pharmacy tells a story about the pharmacy and its philosophies. Immediately I recognized that even chain pharmacies are aware of this. Consider the recent national headlines generated as CVS announced that they would no longer sell cigarettes in their stores. Their rationale was simple: cigarettes are the polar opposite of health care. And while CVS is should applauded for this stance, the chain’s merchandise still includes many items that, while not as polarizing as cigarettes, certainly are not healthy or even related to health and healthcare.
Walking into any pharmacy tells a story. Today, the front end merchandise at many chains bears more resemblance to a grocery or convenience store than a pharmacy. I am sure that this merchandise mix helps draw customers and profits, but it has little to do with pharmacy. Save a few aisles of over-the-counter medications and health supplies, front ends of chain drug stores today are decidedly not health care oriented. Independent pharmacies are not exempt from this phenomena, either. Many smaller independent pharmacies have front end merchandise filled with gift, antiques, cards, and other sundries.
Part of this merchandise mix is tradition, part demographic, and part customer demand. Another part, though, is survival. Today, reimbursement for prescriptions is at an all time low. The pharmacy department historically was the revenue generating area of a store, with the front end almost an afterthought. Today, without strong sales and revenues from the store front end, both independent and chain pharmacies often struggle to generate acceptable profits needed to stay viable businesses.
Independent pharmacies today are at an even bigger disadvantage today than ever before. Independent pharmacies are generally smaller than chains. Their front ends are generally much smaller, too. The strategy being used by chains really does not translate to most independent pharmacies. For the independent, the story the front end tells must be different. For independents, the front end is becoming increasing health-care centered. This differentiation from chain drug stores is one part of how independent pharmacies are trying to survive in the market today.
Our pharmacies have emphasized the apothecary style store for years. Our front end is all health related, and includes the usual assortment of vitamins, wound care, laxatives and other over-the-counter remedies. Included in the merchandise mix is a healthy dose of durable medical equipment, including walkers, canes, crutches, and wheelchairs. Our philosophy is to make the pharmacist accessible, and our pharmacists are positioned on the counter in a manner that they can easily spot customers in the store needing help and quickly step into the front end to offer personalized care and answer questions. The image we want to project is a professional health center.
The next time you enter any pharmacy (chain or independent), take a look around and ask yourself: “what is the image that this store is projecting?” If you work for a pharmacy or even own one, ask your customers the same question, and they ask your self if that is the image you want to project.
On a recent conference call, we learned that a significant Medicare Part D plan would NOT have any clinical opportunities for pharmacists in 2016. This is disappointing on many levels. The fact that Medicare will allow a plan to do this is troubling, especially with the increased lip service being paid by Medicare with respect to quality measures.
Pharmacists should be upset by this, but there is another facet to this that is equally troubling: Medicare Part D plans are not searchable based on clinical services offered. While the Medicare.gov plan discovery tool does display the presence of an MTM program it is not prominent and does not adequately describe the program’s context or extent (see the example below). These omission are significant, especially given the emphasis on quality being touted by Medicare. If a patient considers their local pharmacist to be an important part of their care, and desires to have clinical services (locally provided by their pharmacy) included in their drug plan, they are adrift with little guidance.
While it is possible that Medicare may eventually include clinical opportunities as a searchable term, and / or make differences in how the services are provided more obvious to the end user, it may come down to companies like iMedicare to fill this void in the near term. This company can be used by pharmacies to quickly help their patients choose a plan based on the same information used by the Medicare.gov website. If iMedicare supplemented the information already being provided by Medicare with a description of MTM and clinical opportunities for the given plan, it would allow pharmacists to explain which plans include this important feature. These details on how each plan handles MTM are very valuable, as some plans do not use local pharmacists to perform these clinical services, or severely restrict the number of patients that are eligible. Given this additional information, patients would have a more complete understating of plans and could then make better decisions about their Medicare Part D plans
The other day, my business partner and I had a conference call with our wholesaler and our PSAO about the impact that DIR fees were having on our bottom line. The representative from our PSAO kept emphasizing that the reason why they signed the contracts with some preferred networks (with very low pharmacy reimbursement) is because they wanted to make sure that their network of pharmacies had access to lives. We do not disagree with this statement, but where our priorities began to diverge from our PSAO is when the PSAO representative described ways to increase revenue for those patients in the store. The emphasis was on selling them other items to make up for the losses on the drug product. The emphasis was not on clinical services, but what other products you may be able to offer patients coming to your practice.
What?! We were in disbelief! From our perspective, access to lives means that we have an opportunity to provide clinical services that impacts the care of these patients. If clinically we did our job, then patients should attain their therapeutic outcomes through safe and effective drug therapy regimens. Those patients who achieve their therapeutic outcomes should be healthier and have less health care spend than those patients who do not achieve their therapeutic outcomes. It is our contention that pharmacists SHOULD be paid a FAIR fee for high performance. Obviously, with underwater MACs, DIR fees, claw-backs, and other PBM business practices, the payment for product has rapidly become insufficient to cover the costs associated with dispensing. Product reimbursement certainly leaves nothing to pay for a pharmacist’s clinical activities and cognitive services. To add insult to injury, the performance payment from one PBM for our performance on pharmacy performance measures was extremely anemic. This is unacceptable, and as a profession we should demand more from our strategic partners, which include our wholesaler, our PSAO, our network, our buying group, and the PBMs themselves. At this point, the partnership seems to be benefiting everyone but the community pharmacist who is in the trenches taking care of patients (and who is getting paid less to do this). It makes no sense. But to have one of the strategic partners verbalize that we have to do more than just offer clinical services and look at other products that we can sale to patients as a way to enhance our revenue was enough to put us over the edge.
We want to be good community pharmacists. We offer an extensive list of clinical services. We have partnered with a local payer, who has stayed committed to us because of the outcomes we have been able to generate with their clients (our patients), and we consistently achieve a high performance on our pharmacy performance measures on the EQuiPP platform. We own two professional pharmacies that have small front ends. We only sell medical related items and we already have a flourishing DME business. So if our strategic partners are suggesting that we are suppose to sell paint and hardware or milk and eggs as a way to generate new revenue, then question if they are truly our partner. It should be about patient care. It should be about the services we provide. It should be about the outcomes we achieve. We have worked hard to change the paradigm of our practice, but now we are working just as hard to change the paradigm on how community pharmacist are paid. It seems everyone within the drug distribution system is “making their money” including the all the strategic partners that have been mentioned previously, but the community pharmacist is left to provide the care, identify and resolve drug therapy problems, take calls from patients 24/7, be responsible for patient outcomes, and not paid sufficiently for any of it. Access to lives should not be about finding new ways of selling products to improve the bottom line, but rather it should be about quality patient care, fair reimbursement for that care, and bonus incentives if expectations are met. How can anyone rationally look at the current system and say that it is fair and that pharmacist are reimbursed sufficiently? The financial viability and survivability of independent community pharmacist is on the line.
As we move forward, we will continue to fight for what we believe is fair reimbursement for services rendered. We will continue to put pressure on our strategic partners to help us in our quest for fair and equitable reimbursement. In the short term, we also will continue to put pressure on our strategic partners to make sure that we are receiving the best price for our costs of good sold, including rebates. We will continue to communicate with our legislators about fair reimbursement for pharmacists. And we will continue to support our local, state, and national professional organizations as they continue to fight for pharmacists recognition as providers. It has been a tough year, and next year looks to bring the same. We also realize that we are not alone, as other owners have expressed similar concerns. All of us can make a difference, but we have to be willing to challenge the status quo and our help strategic partners to change.
The other day I sat contemplating the pricing of a large pizza. Yes, I am a bit of a math geek, and I was having trouble wrapping my head around why the price of a 16 inch pizza was only a couple of dollars more than a 12 inch pizza despite the exponential nature of the area as pizzas get larger (113 sq inches for a 12 inch pizza vs 153 sq inches for a 16 inch pizza, almost a 40% increase in size). I am sure someone has looked at all of the variables( ingredients needed, time required to assemble the pie, pizza oven space requirements, baking time etc.) and justified the discrepancy, but it still bothered me.
As I thought about this some more, it occurred to me that pharmacy (and more specifically the pharmacy benefit managers or PBMs) are doing the same thing. The emphasis on the 90 day refill is high in the industry, even to the point of incentivizing the patient with a lower copay (just like pizza) to “upsize” their prescription. Like the pizza industry, I am sure someone has measured all of the variables and come to the conclusion that, like the large pizza, 90 day fills are better.
But is this wisdom actually accurate? Whom does this benefit? Remember that the PBM industry has, by and in large, made this judgment using their variables. Is it good for the payor, the patient, or the pharmacy? What is the goal or outcome that is being sought? To a pharmacist, the goal should be improved outcomes and a decrease in total health care spend. For some reason, I doubt that these are the outcomes cherished by the PBMs.
Benefits of a 90 day “Super Size” Rx
The Patient:
A super size Rx may result in fewer trips to the pharmacy. This assumes that the patient doesn’t visit the pharmacy for other reasons, of course. Patients also pick up necessities at their local pharmacy (think OTC items), receive vaccinations, have their blood pressure checked or cholesterol tested, or to ask questions or advice from their pharmacist. Even after implementing a medication synchronization program, many of our “sync” patients still come the the pharmacy just as often as before. Indeed, fewer trips to the pharmacy may actually be a bad outcome for patients.
Compliance is often touted as a benefit of a 90 day refill. This, however, turns out to be somewhat difficult to prove. Claims data may show better compliance, but it is impossible to know if the patient is actually taking the medication properly and achieving the optimal outcomes with claims data alone. When a pharmacist takes time to talk with a patient, they can actually assess both compliance AND outcomes. Super size refills creates fewer interactions with the pharmacist to assess the patient and can actually delay the pharmacist’s ability to address compliance and intervene to improve outcomes.
Cost is used an incentive for Super Size refills. The patient will often pay less for a 90 day supply than they would for three 30 day supplies. For many patients, this savings, over multiple prescriptions and over the course of the year can be significant.
The Payor:
Insurance companies are the ultimate payor. In the case of Medicare Part D, the payor is Medicare. To the entity holding the purse strings, 90 day fills offer little real advantages. While it is possible that a supe rsize refill costs the payor less than a 30 day refill, drug costs are only a fraction of the costs that the insurance has to consider. Any savings, in the form of improved outcomes from medications can far exceed any savings for 90 day prescription fills. A recent program between a pharmacy in Iowa and a major insurance payor demonstrated that pharmacists can impact total health spend for their patients, and the degree of this impact can be very substantial. Overall, the payor may benefit more from an increase in patient-pharmacist interactions rather than a decrease.
The PBM:
Extended day supplies benefit the PBM in several ways. Many extended day contracts feature both decreased pharmacy reimbursement and decreased dispensing fees (the two places pharmacies are actually paid for their effort). This directly benefits the PBM by decreasing their cost. Another potential benefit is for the PBM to emphasize their own mail-order pharmacy. Extended day fills are really the only way this type of pharmacy can exist. Any emphasis on extended days supply creates opportunity for the PBM owned mail order pharmacies to extend their business.
The Pharmacy:
The pharmacy stands to loose the most from extended day supplies. While the PBM argues that extended day supplies are easier for the pharmacy (only having to fill a prescription 4 times a year versus 12 times a year), this benefit is negated by a myriad of negative economic impacts on the pharmacy, including decreased front end sales and diminished reimbursement of the prescription itself. A prescription, to a pharmacist caring for the patient, is a lot more than just a bottle, label, and drug product. It is a chance to make that encounter with the patient count. Pharmacy is a profession, not a product.
The Real Pharmacy Benefit: Pharmacists
In the end, the PBM industry has pushed its own agenda by forcing down reimbursement for drug product and emphasizing its own metrics. It is time for the patient and the payor / plan to start recognizing the importance what the pharmacist does and how it impacts patient care. It is also imperative that pharmacist step up, if they are not already working as a clinical interventionist. Every pharmacist should be working to make every encounter with their patients count!
We are often asked how our practice evolved into what it is today with it’s diverse service offerings, a significant staff of pharmacists and technicians, and our ability to generate revenue beyond just dispensing medications. It started almost a decade ago when Mike and I decided to change our model of community pharmacy practice. Creating the capacity to provide patient care services was not an overnight fix, rather it was an evolution based on trial and error, feedback from staff and patients, and market forces. This is not saying that our practice developed out of random happenings, but rather we had laid a foundation for which we could easily adjust, improve, and add services as deemed necessary.
To create a capacity for patient care, we began by moving our practice to a technician driven dispensing model, repurposing pharmacists so that the majority of their time was spent evaluating patients’ medications, resolving drug therapy problems, and communicating with both patients and providers. This required changes in job descriptions and responsibilities, new positions being developed, and staff training. We put a lot of our focus on the dispensing pharmacist. Pharmacists traditionally focused performing final verification. In our practice, the pharmacist was asked to becoming a clinical interventionist–identifying and resolving drug therapy problems “on the run” in which we now called continuous medication monitoring (CMM). To make this transition, we had to develop a different documentation system, because our dispensing system, much like all the others, is great for making sure we have all the information needed for dispensing a product, but very limited in terms of documenting patient care. The system we created is now called PharmClin, and it leverages the information from our dispensing system and creates a clinical record, making it easier and more efficient for the dispensing pharmacist to provide CMM. Moving the pharmacist into this new role also required education and training on how to quickly clinically assess patients’ medications, develop an intervention to resolve medication issues, and document their patient care activities. Obviously, creating the technician driven dispensing process helped to free up the pharmacist more to focus their activities on patient care. We saw the need to create a new position for a pharmacist to oversee the operations of our dispensing system.
In addition to the changes in dispensing, simultaneously we remodeled our pharmacy to include two patient care areas. These areas are used to provide clinical services beyond the CMM process. Services included immunizations, medication therapy management services (MTMs), adherence programs, health promotion services, and case management. As our services continued to expand and more and more patients enrolling in them, it was time about adding some new positions. We created a community pharmacy resident position, but quickly realized that we also needed to hire another pharmacist to oversee all of our clinical services. Not only do these pharmacists manage our clinical services, but they serve as a resource for our dispensing pharmacists providing us with “slack resources” for more in-depth problems uncovered by the dispensing pharmacists, or providing more in-depth counseling to patients as needed.
Other features of our practice that help support our patient care services a marketing plan that we review monthly. Every month we determine which services or practice areas we want our marketing efforts to focus on and what media we will use to “spread the word”. We hired a marketing professional who oversees our marketing efforts.
We have remodeled our pharmacy several times in the past decade with each remodel planned to improve patient care processes. We created two patient care areas which also serve as offices for our clinical manager and our community pharmacy resident. We expanded our dispensing counter to give our dispensing pharmacists more room for their CMM activities. We also created a patient counseling area at the end of our dispensing counter.
We have implemented tech-check-tech services as part of a new practice model program in Iowa to free up our pharmacists to provide clinical services. We also have implemented new technologies in the practice to improve our efficiencies including using a Parata robot, the Eyecon medication counter, an interactive voice response (IVR) system, and automated programs that help with our medication synchronization program and help with patient selection into medicare plans.
With all of these changes, the following list provides the current patient care services we offer at Towncrest Pharmacy
Clinic Services: Med Check Program, Medication Adherence Program, Influenza and Pneumococcal Vaccinations, Zostavax Vaccination, Tdap Vaccination, Pharmaceutical Case Management (PCM), Medication Therapy Management (MTM), Nursing Home Consulting, CPAP service/Education, Ostomy Consultations, Drug Information Service, Compounding, Employer based health screenings
Wellness Center: Cholesterol screening, Blood glucose screening, BP screening, Height and Weight, BMI
Specialized Focused: Mental Health, Wellness, Geriatrics, End of life/palliative care
As we have mentioned before, our practice has evolved to have this type of capacity to provide patient care services to all of our patients. Although it didn’t happen overnight, we realized that we had to make the initial changes to provide the foundation.