Arlington, Va. – In comments to the Department of Health and Human Services (HHS) Office of the Inspector General (OIG), the National Association of Chain Drug Stores (NACDS) advocated for the voluntary ability of pharmacies to extend their popular reward and loyalty programs to beneficiaries in government programs, including Medicare and Medicaid. While urging progress on HHS-OIG’s proposed rule to this effect, NACDS indicated modifications that would be necessary for its workability.
“The proposed rule, if properly finalized, will allow government program beneficiaries to enjoy access to programs voluntarily implemented by pharmacies which reduce healthcare costs, improve quality, and promote patient health,” NACDS wrote.
Federal laws have blocked participation by government-program beneficiaries in such initiatives, even though these initiatives have been enjoyed by other patients for many years. Programs vary in their specific designs. They often include cost-savings or other rewards for filling prescriptions or engaging in other health-promotion programs, such as health screenings or strategies designed to enhance medication adherence – or taking medications as prescribed.
“Pharmacy programs affected by the proposed rule reduce healthcare costs, both for individual patients and for the healthcare system as a whole. At the same time, these pharmacy programs promote access to prescribed medications that are essential to maintaining patient health and wellness,” NACDS commented.
“Failure to take medications as prescribed leads to major healthcare complications for patients and $290 billion in increased healthcare costs as a result of preventable physician visits and hospitalizations. Incentives to participate in medication adherence and other beneficial pharmacy programs have a demonstrated track record of increasing patient health while simultaneously decreasing overall healthcare costs.”
NACDS noted that non-government payers and patients have found these programs to be effective, without contributing to overutilization of care.
While supportive of the intent of the proposed rule, NACDS detailed necessary revisions. In one example among a series of recommended revisions, NACDS urged elimination of a provision that pharmacies must not voluntarily offer to waive or reduce cost-sharing, or co-payments, as part of an advertisement or solicitation.
“There is no rational basis for prohibiting pharmacies from informing the public about programs that reduce healthcare costs and promote access to prescribed medical care. OIG should recognize pharmacies’ First Amendment rights and eliminate this restriction,” NACDS wrote.
The comment period for the proposed rule ends December 2, 2014.
