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While AMCP supports access to appropriate medication therapies, this access must be balanced with cost considerations to ensure the affordability of the entire benefit, a point that was made in an
The EHB proposed rule, issued
By contrast, under the new EHB proposed rule, plans starting in 2014 would be required to provide at least the greater of: (a) one drug in every category and class or (b) the same number of drugs in each category and class as the "benchmark plan" – i.e., the plan selected by state officials as representing a typical employer plan in that state. Under this standard, if a benchmark plan offers more than one drug per category and class, then all plans would have to have at least the number of drugs in the benchmark plan.
"This rule would restrict the ability of health plans to design pharmacy benefits that are scientifically based and financially prudent for their member populations, as outlined in the IOM report," said AMCP Chief Executive Officer
Rosato continued, "AMCP has long contended that plans should have the flexibility to design effective benefits through their pharmacy and therapeutics committee's evaluation of medicines, and not through a regulated category and classification structure. This gives plans the ability to provide the best value and choice to patients."
On another pharmacy related topic, the 2012 proposed rule for EHBs requires plans to report "drug lists" (the term formulary is not used) to government entities using the United States Pharmacopeia's (USP) classification system. In earlier comments, AMCP had opposed being restricted to using one classification system with a single compendium.
"Requiring the use of the single classification system may impose an undue obstacle on the development of appropriately evaluated and valid formularies," said Rosato. "We will continue to express our concerns with this rule and explain our position to HHS officials."
These and other regulations regarding prescription drug coverage were part of the proposed rule on standards of coverage for EHBs. This rule, in turn, was one of three proposed rules published
AMCP is carefully reviewing all of the proposed rules and will provide comments by the