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Improving Outcomes and Controlling Costs:
TAC Health Pool Pharmacy Program Changes
47th Annual County Treasurers' Association of TexasContinuing Education Seminar
April 17, 2019
Quincy QuinlanCharlotte CollinsVirna JamesonJennifer RehmeHealth and Benefits Services DepartmentTexas Association of Counties1210 San AntonioAustin, TX 78701(512) 478‐8753 (office)(800) 456‐5974 (Texas toll‐free)(512) 481‐8481 (fax)[email protected]
Discussion Agenda
Prescription Drug cost analysis What is a PBM and what does it do TAC HEBP’s decision to change PBM
Pharmaceutical spending in 2017: over $328 billion for 4.3
billion prescriptions
Projected to be over $520 billion by 2021‐ a 58% increase ‐
Pharmacy costs represent 9‐14% of total healthcare spending nationally, with fastest increase in upward trend
Pharmacy costs are ~25% of TAC health pool claims cost
Why are drug prices so hard to control?Government does not have pricing controls
The government currently has little leverage over how much drug manufacturers are paid.
CMS is not allowed to negotiate drug prices for Medicare programs (42+ million patients)
The pharmaceutical industry lobby spent over $281 million in 2017, in large part to keep these situations from changing.
Limited regulation along the supply chain.
Paying for drugs isn’t a simple matter of what the manufacturer charges. Manufacturers sell to wholesalers, who sell to pharmacies.
Pharmacies bill health plans for the portion of cost not paid by the patient.
Pharmacy benefit managers (PBMs) act as middlemen to negotiate which drugs are covered and how they are priced.
Why are drug prices so hard to control?
Limited regulation along the supply chain.
Money is retained at each level of the supply chain, including the rebates
Critics say these rebates incentivize PBMs to favor higher‐cost drugs or charge insurers more than they’re charging the pharmacy — and the PBM pockets the difference.
PBMs say the rebates help keep the costs down
Why are drug prices so hard to control?
Drug manufacturers manipulate the market
Why are drug prices so hard to control?
Manufacturers make minor changes to branded drugs in order to extend patent so that no generic can be released (such as making an ‘extended release’ version).
Manufacturers increase cost of drugs (with no explanation) that have been on the market for years (example: Epipen).
Drug manufacturers manipulate the market
Why are drug prices so hard to control?
Manufacturers combine inexpensive generic and/or over‐the‐counter medications to create a “new” drug that is branded and costs significantly more than if the individual meds were purchased separately.
Example: The medication Duexis is a combination of ibuprofen and famotidine (generic Pepcid). These 2 medications purchased OTC would cost less than $5, while a prescription for Duexis costs ~$2000.
Drug manufacturers manipulate the marketWhy are drug prices so hard to control?
GlaxoSmithKline fined $490 million for paying bribes to doctors and hospitals for promoting its products (Advair……)
AstroZeneca fined $5.5 million for similar charges (Crestor)
Novartis AG faces a U.S. government lawsuit accusing it of paying millions of dollars in kickbacks to doctors so they would prescribe its drugs (Ritalin, Clozaril….)
Drug manufacturers manipulate the marketWhy are drug prices so hard to control?
Drug companies use coupons to lower prices for consumers while they raise their medications’ list prices.
Drug companies offer coupons to customers to incentivize them to buy brand‐name drugs rather than generics. While these coupons lower
consumers’ out‐of‐pocket costs, theyensure their insurance plan pays for more expensive drugs.
Someone has to pay for all those pretty commercials.
Drug manufacturers spend 2.5X more on advertising and administration than
on research and development
Why are drug prices so hard to control?
The pharmaceutical industry spent $6.1 billion on direct‐to‐consumer advertising in the United States in 2017, a practice that is either banned or severely limited in most other developed nations.
Senate hearing puts spotlight on debate over consolidation in PBM market
Senate works on bills to support Administration's proposed ban on drug rebates for PBMs
Bi‐partisan bill would link a drug’s price to its clinical effectiveness
Congress putting pressure on drugmakers and PBMs to address steep insulin prices
Federal budget proposal includes changing FDA practices to increase generic drug access
What is a PBM?PBM stands for ‘Pharmacy Benefit Manager’
Health plans contract with PBMs to manage the prescription drug component of the plan.
24/7, toll‐free ‐ (866) 333‐2757All calls greeted LIVE (after 1 prompt)Callers enjoy a single point of contact for pharmacy benefit inquiriesPharmacists available 24/7 for clinical needs, such as cost overrides
Responsibilities of a PBM
PBM Conflict of InterestConflict of interest occurs because the PBM, which should be representing the interests of the plan sponsor, is at the same time negotiating payment arrangements with drug manufacturers and wholesalers, which allow the PBM to make money.
There are over 30 labels for these payment arrangements – 1 or 2 of them are “rebates”.
Pricing and RebatesDrug manufacturers and wholesalers inflate the ‘list price’ of drugs in much the same way as car manufacturers. No one pays the “sticker price”, but in the PBM space, plan sponsors usually never know the true price of a drug.
The push for higher rebates usually means purchasing higher cost drugs.
The increased rebates do not offset the higher costs.
PBMs and guaranteed discounts
Suppose your grocery store’s weekly ad says “Fish $1.50/pound”. You happily go in to shop for your favorite, only to discover that, by the store’s definition this week, “fish” only includes catfish and tilapia.
PBMs and guaranteed discountsSimilarly, PBMs “guarantee” plan sponsors specific discount and rebate guarantees on various drug classifications, such as brand, generic, and specialty.
The problem is that PBMs often move drugs between classifications to make it appear they’ve met their guarantees – and the plan sponsor has no way of determining when this has happened.
It’s a little fishy!
TAC HEBP contracted with CVS Caremark for 17 years as the Pool’s PBM
The Pool did an RFP in 2018 and contracted with Navitus Health Solutions as our new PBM
HEBP History with CVS Caremark
2001 2018
The Pool’s relationship with CVS Caremark was always positive, and they helped us grow over the years; however there were issues: Significant cost increases year over year, no
mechanism for controlling them Open Formulary – most drugs covered. No idea
what drugs really cost or why they were/were not included
ANSWER: It was broken.
The Pool’s existing PBM contract, like most PBM contracts, was riddled with loopholes and vague language which allowed the PBM to earn more and more money, while the Pool paid higher and higher claims.
$0.00
$10,000,000.00
$20,000,000.00
$30,000,000.00
$40,000,000.00
$50,000,000.00
$60,000,000.00
$70,000,000.00
2009 2010 2011 2012 2013 2014 2015 2016 2017 2018
Plan Paid w/ CVS Caremark
Problems with ‘standard’ PBM contracts Sharp limitations on TAC’s access to data (even
claims data that documents what the PBM was asking the plan sponsor to reimburse);
Unclear or heavily ambiguous definitions (or even silence) for important terms;
Limitations on audit rights and stringent approval process for audit firms (including excluding some audit firms from the ability to act on behalf of a client);
Problems with ‘standard’ PBM contracts, cont.
A lack of clarity in the PBM’s drug pricing algorithm;
A lack of transparency in the PBM’s retail pharmacy network contracts (a PBM may have multiple contracts with the exact same retail network);
A lack of disclosure as to the financial incentives the PBM may receive from drug manufacturers and/or wholesalers;
Problems with ‘standard’ PBM contracts, cont.
Pricing disparities between retail dispensed drugs and the cost of the same drug dispensed by the PBM’s mail order facility;
Definitional issues between generic versus brand drugs; and
A habit of directing patients to higher cost therapies just prior to the therapy losing patent protection.
RFP process took 9 months5 PBMs responded
The RFP Contract was 161 pages long (Pool’s existing contract was less than 1/3 of that) with 3 additional exhibits and an exhaustive list of prescription drugs.
The contract requires the PBM to:
Provide TAC HEBP with the net cost of all drugs
Agree to specific definitions for drug classifications, with no ability to move drugs between classes without TAC HEBP’s permission
Pass‐through all $$ received from manufacturers and wholesalers
Allow TAC HEBP to customize the drug formulary
Incumbent PBM refused most contract changes but almost doubled rebate guarantee (where had all that extra money been going?);
1 PBM refused all contract changes;
1 PBM attempted to make some contract changes but ran out of time to negotiate;
1 PBM made most contract changes but did not agree to full pricing transparency;
Navitus agreed to most contract changes and full price transparency.
Drug Savings Review: looked at the 200 most expensive drugs covered by the PoolThe main actions that TAC HEBP can employ to generate savings include:
Implement a Mandatory Generic Program Implement a Prior Authorization ProgramExclude the drug from coverage Implement a Step Therapy ProgramImplement a Quantity Limit Program
Example: Three Therapeutic Categories and Lidocaine Gel: Approximate Savings $2,016,989 to $2,037,362 The greatest savings TAC HEBP can generate concern drugs that have multiple replacements available over the counter.
These drugs cover 3 therapeutic categories –Proton Pump Inhibitors (PPIs) such as Nexium and Dexilant, nasal steroids such as Flonase, and non‐sedating antihistamines such as Zyrtec, as well as Lidocaine topical 5%.
Possible approaches for PPIs:
Stop covering PPIs entirely, as over‐the‐counter therapeutic equivalents are available
Cover all or some PPIs with a Mandatory Generic Program, making the beneficiary pay the differential between a low‐cost “reference price” and the cost of the beneficiary’s selected drug
Cover only omeprazole and a few other low‐cost PPIs (chosen alternative)
PPI pricing on 2017 formulary
Covered on new formulary
BrandnameCost per 30‐Day
Supply Comment
ACIPHEX 478.53$ ExcludeACIPHEX SPRINKLE 476.75$ Exclude
DEXILANT 254.17$ ExcludeDUEXIS * 2,077.33$ Exclude
ESOMEPRAZOLE MAGNESIUM
174.59$ Exclude
LANSOPRAZOLE 47.70$ CoverNEXIUM 190.97$ Exclude
OMEPRAZOLE 30.16$ CoverOMEPRAZOLE‐
SODIUM BICARB *1,928.29$ Exclude
PANTOPRAZOLE SODIUM
22.95$ Cover
PREVACID 376.32$ ExcludePRILOSEC 74.21$ Exclude
RABEPRAZOLE SODIUM
76.63$ Exclude
VIMOVO 2,158.45$ Exclude * combination of 2 OTC medications
Example: Auto-immune TreatmentsApproximate Savings $1.06 to $2.138 million
Some patients begin treatment for an autoimmune disorder, like rheumatoid arthritis, using an expensive biologic agent (like Enbrel or Humira), before they try a less expensive treatment like methotrexate (~$20 for 30‐day supply).
The new formulary includes a Step Therapy program requiring newly diagnosed patients to try the less‐expensive drug as a first‐line treatment before moving to more expensive medications.
Auto-immuneTreatments
Brandname Cost per 30‐Day
Supply CIMZIA 4,653.10$
COSENTYX PEN (2 PENS)
5,594.07$
ENBREL 4,895.99$ HUMIRA 5,457.10$
HUMIRA PEN 5,620.29$ HUMIRA PEN
CROHN‐UC‐HS STARTER14,259.77$
HUMIRA PEN PSORIASIS‐UVEITIS
8,231.44$
ORENCIA 4,155.53$ OTEZLA 2,969.61$ STELARA 6,580.25$ TALTZ
AUTOINJECTOR7,728.73$
XELJANZ 3,843.51$ XELJANZ XR 3,845.65$
Prices on 2017 formulary
Methotrexane: less than $25 for 30‐day supply
Formulary Management• Ensure availability of products that provide evidence‐based clinical value
• Manage to the overall lowest net cost• Unique tier placement
•High‐cost/non‐preferred generics on Tier 3• Lower‐cost brands on Tier 1
• Apply utilization management tools to ensure products used provide best value
Lowest Net-Cost Approach
DefinitionsTotal Cost = Plan Paid + Member PaidNet-Total Cost = (Plan Paid + Member Paid) – RebateNet-Plan Cost = Plan Paid – Rebate
Pharmacy and Therapeutics(P&T) Committee
• Includes 14 non‐Navitus practicing physicians and pharmacists
• Represents a variety of specialties• Determines drugs that provide best value
(clinical and cost) for members• Recommends utilization edits
(e.g., PA, step therapy, & quantity limits)• Meets quarterly; open to plan sponsors
TAC HEBP contracts with an outside, independent pharmacy consulting firm to review Navitus’ formulary decisions and monitor their compliance with contract terms.
Rollout of new pharmacy program
Provided webinars, videos on website, articles in County magazine and Healthy Byte newsletter, fliers at conferences, information in annual renewal and open enrollment materials, and mailed postcards to all members.
Grandfathered all but a few drugs for first 90 days.
Permanently grandfathered most drugs for treatment of cancer, rheumatoid arthritis, MS, and ADHD for members who were already taking the drug.
Challenges:
Confusion at Navitus customer care ID cards late Change from Brand /Generic copays to
Tiered copays Navitus only had access to 12 months of claims history, so in some cases Prior Authorizations and Step Therapy requirements were requested when patients had already taken those steps.
Challenges:
Pharmacies attempted to process refills for patients under old Caremark coverage Difficulty transitioning mail order prescriptions to Costco Flu shots not processed at $0 for some Diabetic supplies – Medicine Match discount not applied
Responses:
Reacted as quickly as possible to members who were unable to fill prescriptions due to programming or customer service errors
Refunded members who paid for flu shots
Re‐evaluated formulary and moved some generics back to Tier 1
Refunding members of Medicine Match for diabetic supplies (in process)
Results:
Volume of customer service calls is back down to pre‐transition levels
Pool’s pharmacy costs dramatically decreased since October 1, 2018
Ongoing formulary review with independent consultants and Navitus to ensure best therapies are available to members at the most competitive cost
Month Total Cost Plan PaidPlan Paid PMPM Mem Paid
Mem Paid PMPM
2017 October (CVS)$5,812,333.86
$5,110,479.23
$146.58
$701,854.63
$20.132017 November (CVS) $5,621,423.31
$5,042,197.28
$144.67
$579,226.03
$16.622017 December (CVS) $5,584,869.19
$4,953,325.25
$141.37
$631,543.94
$18.03
2017 4Q Totals $17,018,626.36 $15,106,001.76
$144.21
$1,912,624.60
$18.262018 October (Navitus) $4,656,378.78 $3,914,270.52 $108.81 $643,838.63 $17.902018 November (Navitus) $4,797,241.93 $4,114,852.39 $114.22 $571,159.36 $15.852018 December (Navitus) $4,878,516.66 $4,157,053.24 $114.93 $555,559.91 $15.36
2018 4Q Totals $14,332,137.37 $12,186,176.15
$112.65
$1,770,557.90
$16.37
% Change ‐15.79% ‐19.33% ‐21.88% ‐7.43% ‐10.34%
2018 4th Quarter PBM Comparison: