Enabling Healthy Decisions

To Whom It May Concern:

You should be embarrassed to produce this bill. It’s obviously based on a one-sided view of the world regarding Pharmacy Benefit Managers which is generated by sensationalist journalists, jilted employees, independent pharmacists who have lost marketshare to chain drugstores, and pharma manufacturers who have seen their marketshare decline. This type of legislation will only serve to drive up healthcare costs and is exactly the reason why a government run plan won’t work in this country. They’ll focus on lobbyist interests and not the true interests of the consumer.

Let’s go point by point through your legislation and point out some flaws – (see bill here)

1 – Why would a PBM have to tell a consumer what they pay the pharmacy? That’s like Best Buy being required to tell the consumer what they pay for a TV. Most PBMs and/or pharmacies often print on the receipt what the consumer’s payor (employer, managed care company) paid for the drug (i.e., your insurance saved you $100).

2 – Why is the government telling businesses how to do their job? As an HR manager, if I can get a better discount for my employees on their prescription drugs by limiting the pharmacy network, why shouldn’t I have that option. We have preferred vendors in most companies. Why shouldn’t that be true in pharmacy? There are ~60,000 pharmacies in the US which is more than enough.

3 – Again, why is the government interfering in pharmacy law and telling me (the consumer) what I can or can’t do? Why can’t I move my prescription from one pharmacy to another based on discount, convenience, service, or other issues? All you are doing is creating a consumer burden and physician burden with no benefit to anyone.

4 – Now you want to take away my ability to manage drug coverage. There are plenty of circumstances where limiting or denying coverage makes sense due to inappropriate utilization, availability of lower cost options, abuse, and other issues.

5 – I’m completely confused here. You want to tell the insurance companies that they can’t increase the percentage of costs that the member pays (which is really a benefit design issue for the employer) unless the drug prices go up.

6 – This topic has been discussed a lot around switching medications. Of course, the communications should be clear. The patient should understand their choices. They physician should be in the loop (which they are since they have to write the new prescription). You hopefully realize that these are done to lower healthcare costs AND that physicians neither discuss costs with patients (generally) nor do they believe it’s their job to do this.

7 – Do you really believe that the dispensing physician who is focused on caring for their patients has the time to keep up with all the medical literature that a Pharmacy & Therapeutics (P&T) Committee reviews in determining protocols around step therapy? Look at the research…it shows that it takes 17 years for evidence-based standards to become standard practice. I personally don’t want to rely on my individual physician (who does a damn good job) to understand all the latest literature (w/o an EMR). And, I would hope no MD would willingly write an Rx that causes harm. All step therapy programs offer a prior authorization override to the MD and the PBM systems look for drug-drug and other types of interactions.

So, I guess the question is why are you (the legislation) trying to force me (the consumer) to have more administrative headaches, higher costs, and be treated with outdated protocols? And, at the same time, you’re going to force my employer to have higher costs and likely have to stop offering healthcare. And, you’re going to put more administrative burden on my physician who is already overworked and potentially underpaid.

Oh, wait, I get it…If you make the existing companies unable to run their business and unable to use evidence-based standards to lower costs then a government run experiment in socialized medicine will look much better. I hope that the Obama camp recognizes you for your hard work in advocating for them.