“Until drug manufacturers reduce the high price they set for these drugs, we know this problem is not going away,” the corporate stated within the letter. “We support the Administration’s goal to lower drug prices and reduce out-of-pocket costs for consumers and we are using every innovative tool possible to bring down the cost of drugs ourselves.”
The complete textual content of CVS Well being’s cowl letter to Secretary Azar follows right here:
Secretary Alex M. Azar II
Division of Well being and Human Providers
200 Independence Ave. SW, Room 600E
Washington, DC 20201
Re: Response to the Well being and Human Providers Blueprint to Decrease Drug Costs and Scale back Out-of-Pocket Prices
Pricey Secretary Azar:
CVS Well being appreciates the chance to remark on the request for info included within the Well being and Human Providers (HHS) Blueprint to Decrease Drug Costs and Scale back Out-of-Pocket Prices revealed within the Federal Register, vol. 83, no. 95 (Might 16, 2018).
CVS Well being is a pharmacy innovation firm serving to individuals on their path to higher well being. Caremark, our pharmacy profit supervisor (PBM) firm, supplies providers to plans masking 12 million Medicare Half D beneficiaries, together with SilverScript, our nationwide Medicare Half D plan, which covers roughly 6 million beneficiaries. Via our greater than 9,800 retail pharmacies, greater than 1,100 walk-in medical clinics, devoted senior pharmacy care enterprise servicing multiple million sufferers per yr, and increasing specialty pharmacy providers, we allow individuals, companies, and communities to handle well being care in a extra reasonably priced, efficient methods. Our distinctive built-in mannequin will increase entry to high quality care, delivers higher well being outcomes, and helps to lowers general well being care prices.
We see the influence rising drug costs have on our sufferers day by day. Our pharmacists witness the sticker shock first hand as sufferers query the worth of brand-name medicine, particularly as costs have grown 10 occasions quicker than inflation during the last 5 years. And till drug producers scale back the excessive worth they set for these medicine, we all know this drawback is just not going away. We help the Administration’s aim to decrease drug costs and scale back out-of-pocket prices for shoppers and we’re utilizing each progressive device potential to convey down the price of medicine ourselves.
All through our response to this request for info (RFI), it’s clear that coverage options that decrease drug costs for well being plans and shoppers and scale back out-of-pocket prices are aligned with our objective of decreasing healthcare prices and serving to enhance healthcare outcomes. One of many key roles of presidency is to present a regulatory framework during which the personal sector can innovate and convey cost-saving options to the marketplace. This implies creating an setting that permits personal sector instruments to be used extra successfully. The federal government’s imaginative and prescient for the longer term ought to encourage trendy instruments and innovation from the personal sector and CVS Well being is proud to be a pacesetter on this area.
As a pharmacy profit supervisor, CVS Well being negotiates the bottom attainable value from drug producers for our shoppers, that are well being plans, employers, unions, authorities packages like Medicare Half D and Medicaid, and finally for the hundreds of thousands of People who decide up their prescriptions at pharmacy counters day by day. Even in an setting the place the record costs of medicine are regularly rising, we stored drug worth progress at a minimal zero.2% in 2017, the bottom in 5 years, regardless of producer model record costs will increase on medicine close to 10%. Additional, over 30% of our shoppers spent much less per member in 2017 than they did in 2016 on prescription drug prices. We return over 95% of rebates to business shoppers and their members. For Medicare Half D plans, successfully 100% of the rebates are handed by means of to assist decrease premiums, which scale back prices for each the beneficiary and the federal government. The instruments utilized by pharmacy profit managers to take away prices from the well being care system are projected to save $654 billionon drug prices over the subsequent decade.1
At present, CVS Well being supplies availability of rebates on the point-of-sale as an choice for all shoppers. As well as to serving to shoppers scale back out of pocket prices, this strategy demonstrates the true reason for rising drug costs for shoppers, which is the worth set by pharmaceutical producers. For shoppers in excessive deductible well being plans, the supply of level of sale rebates on their drugs earlier than their deductible is met, could be a key answer to assist shoppers keep adherent on their important drugs by making them reasonably priced.
However we don’t cease there. We’re additionally utilizing an revolutionary know-how answer to convey real-time advantages info to the purpose of prescribing. By way of their digital well being document system, prescribers are in a position to see member-specific out of pocket prices for a specific drug based mostly on the place they’re at that second of their deductible and up to 5 lowest-cost clinically applicable therapeutic options, particular to the member’s formulary.
We’ve got additionally introduced this know-how to the pharmacy counter. Our almost 30,000 pharmacists make the most of the Rx Financial savings Finder software to shortly determine obtainable financial savings alternatives when beneficiaries current their prescriptions. This software is predicted to produce a mean of $420 in further annual financial savings for the affected person.
Our pharmacists are dedicated to serving to sufferers discover probably the most reasonably priced choices, and we make sure that pharmacists in our Caremark networks do the identical. Accordingly, CVS Well being doesn’t interact in gag clauses, and we help efforts to ban them.
Regardless of our efforts to decrease prices for shoppers, we’re working inside a system the place competitors has been stalled, which hurts the buyer most. As you will notice in our response, we consider growing market competitors by making extra generics out there is completely vital to make an actual impression. We’re proud to have provided a generic epinephrine auto-injector on the lowest money worth out there as a method to fight the exorbitant worth will increase within the model drug, EpiPen. We’re happy to see the Meals and Drug Administration’s (FDA) efforts to velocity approval of generic drug purposes and to prioritize evaluate of medicine with just one producer to encourage competitors. A good enjoying subject isn’t just about generics although, we should increase using biosimilars and get rid of the techniques that stall competitors.
Whereas we have now offered responses to most of the questions posed within the RFI, there are 4 major areas we want to spotlight the place the Administration can take speedy steps to assist scale back prices for shoppers. They embrace:
1) With extra People now coated via a excessive deductible well being plans with an related well being financial savings account (HSA), hundreds of thousands of shoppers are seeing higher-out-of-pocket prices on the a part of the profit they use most—their prescription drug protection—as a result of they typically wouldn’t have full prescription protection till they’ve met their deductible. Beneath present Inner Income Service steerage for HSAs, solely sure preventive services could also be coated by a excessive deductible well being plan prior to satisfaction of the minimal deductible. We urge you to increase protection of preventive services to embrace merchandise for managing persistent circumstances, or to permit a excessive deductible well being plan to cowl medicine prior to satisfaction of the deductible. This might assist these plans present extra first greenback protection on the pharmacy counter, enhance treatment adherence and well being outcomes and scale back sticker shock when shoppers are filling their prescriptions. You possibly can accomplish this instantly by way of the regulatory or steerage course of.
2) As talked about above, we now have seen nice outcomes from prescribers accessing the real-time advantages info to the purpose of prescribing. Via the digital well being data system, suppliers are in a position to see the member-specific value for a specific drug, based mostly on a member’s protection, together with various choices based mostly on the affected person’s formulary. For prescriptions written by physicians utilizing actual time advantages and crammed by the member; when a lower-cost most popular various is introduced, physicians are switching to the decrease value various 40% of the time. In these instances the member value was $130 decrease per fill, in contrast to the unique non-preferred drug chosen. Physicians who’re utilizing actual time advantages are switching to a coated drug 75% of the time when the unique drug shouldn’t be coated. We might encourage the Administration to use each regulatory device at your disposal to incentivize the adoption of level of prescribing actual time profit info. This may save sufferers a big sum of money.
three) Competitors amongst model medicine and generics are necessary in decreasing drug prices. The growing use of biosimilars will convey competitors into biopharmaceutical market. The Administration ought to search to improve competitors within the drug market by way of FDA’s actions as quickly as potential. Extra have to be accomplished to make generics obtainable, together with increasing using biosimilars, and eliminating techniques that stall competitors. To extend the supply of biosimilars, we consider the Administration ought to help shortening the exclusivity interval for biologics from twelve to seven years, and finalize interchangeability steerage, which is vital to increasing adoption of those decrease value options. By prohibiting pay-for-delay agreements, the Administration can curb anti-competitive practices and assist convey decrease value, clinically-equivalent generic drugs to market extra shortly. CVS Well being additionally firmly helps the bipartisan CREATES Act to cease the abuse of Danger Analysis and Mitigation Methods, which prices the well being care system $5.four billion yearly by protecting generics from getting into the market. We might encourage the Administration to additionally help the CREATES Act.
four) Lastly, we help the Administration’s proposals to strengthen negotiating instruments in Half D, together with by offering higher formulary flexibility, which can assist construct upon this system’s profitable document of delivering reasonably priced drug advantages to seniors at a price far lower than initially projected.
We respect the chance to present feedback on the HHS Blueprint, and we welcome alternatives to work with the Administration to decrease drug costs and scale back out-of-pocket prices for shoppers.