Editor’s Note: This month, we offer updates on three topics: Changing Pharmacy Reimbursements for CVS, FSS/IFF Reporting Alert, Latest in 340B Drug Discount Program. As always, if you have questions on any of the content found in this or previous market updates, please reach out to your IntegriChain Consulting Lead or consulting@integrichain.com and we would be happy to talk you through it.

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Changing Pharmacy Reimbursements for CVS

CVS Health has announced its plan to revamp pricing strategy for prescription drug medication. This move aims to simplify the complex pricing model that has long been a pain point for patients, pharmacists, and payers alike.

As for their vision for change, here is what we know so far. 

Transparency: CVS plans to provide greater transparency by offering “client pricing reflecting the true net cost of prescription drugs, with visibility into administrative fees.”

Integration of Care: CVS intends to roll out CVS Healthspire that will focus on delivering “connected patient care, pharmacy benefits, and innovative provider support solutions in communities across the country.”

This new change could have potential benefits to the current healthcare system. By focusing on delivering care with reducing costs, it would help improve health outcomes and the patient experience, especially for those with chronic conditions. Other players in the pharmaceutical ecosystem—such as drug manufacturers, PBMs, and insurers—will closely watch CVS’s experiment. If it succeeds, we may see similar shifts elsewhere.

Sources:

• CVS Plans to Overhaul How Drugs Are Priced
• CVS Health Highlights Path to Accelerating Long-Term Growth

FSS/IFF Reporting Alert

VA FSS has closed the old FSS/GSA “VA Sales Portal.” In its place, manufacturers must transition their FSS sales reporting and IFF remittance duties to Federal Acquisition (FAS) Sales Reporting Portal at https://srp.fas.gsa.gov/.

The new system goes live April 1, 2024. We recommend all manufacturers attempt to sign into the new portal before the due date of the next reporting cycle to identify any sign-on problems. If you have trouble, you may contact the GSA Monday through Friday, 8:30 am to 5:30 pm EDT at 877.495.4849 or vendor.suport@gsa.gov. For questions specifically related to the FAS Sales Reporting Portal, you may write to FSSRP@gsa.gov.

Latest in 340B Drug Discount Program: Draft Reform Bill “Sustain 340B Act”

Bipartisan senators issued an initial discussion draft bill and a request for information (RFI) to help curb the existing 340B abuse that has been long standing in the industry–leading many manufacturers to institute their own guidelines surrounding which entities they opt to provide discounted prices to. The 340B Program does not allow manufacturers to “discriminate” who they can and cannot provide 340B ceiling prices to; however, with the growing number of contract pharmacies and lack of appropriate transparency in place, manufacturers have felt the need to halt what they believe are out of control practices by covered entities.

The draft bill contains a few key provisions that help curtail the impropriety from both manufacturers and covered entities/HRSA.

• Prohibits manufacturers from placing restrictions on 340B drugs provided to covered entities that contract with contract pharmacies
• Requires hospitals to register their contract pharmacies with Health & Human Services (HHS) annually
• Requires hospitals to be more transparent in their processes and provide information required by manufacturers including the number of patients provided drugs at the 340B price
• Recommends charging of user fees to oversee the program, which would be no greater than [.01]% of the savings the covered entity receives under the 340B Program
• Recommends establishing a clearing house for rebate claim scrubbing to prevent duplicate discounting, an area many manufacturers have struggled with for years

Additionally, the reform bill also proposes to provide clarity to the term “patient” to obtain alignment on what constitutes an “eligible” patient. The clarification requirement stems from the Genesis court hearing where the term “patient” was at the crux of the case. 

Lastly, the bill also contains a provision to prohibit discriminatory practices towards covered entities and contract pharmacies from PBMs and GPOs.

If you have any questions or want to discuss any potential implications of the draft 340B bill to your business, please reach out to your IntegriChain Advisory point of contact or send an email to Consulting@integrichain.com.

Sources:

• Senate Releases Draft 340B Bill
• Senators Seek Input on Draft 340B Reform Bill
• Draft 340B Reforms Include User Fees