At a recent Medical Care Advisory Committee (MCAC) meeting, Bryan Amick, Pharmacy Director for DHHS, discussed a pharmacy reimbursement advisement. CMS has finally published the final rule on covered outpatient drugs, and this advisement (below) will bring the state into line with the new rules. He said pharmacy reimbursement has a dispensing fee and a drug cost, and the regulations require states to move to an actual acquisition cost (AAC) instead of an estimated acquisition cost (EAC). CMS has established a national average cost survey that the department would use. There also has to be a professional dispensing fee because CMS says it brings about a fairer dispensing fee to separate the ingredient cost. Twelve states have implemented a similar program already, and all states are required to comply by April 1, 2017. The fee should be cost neutral. The current dispensing fee of $3 will be changed to whatever amount is necessary to keep it cost neutral.

The department also has to articulate how it is going to implement the 340B system. The options are to not allow 340B providers to use those drugs for the Medicaid population, but that is a burdensome approach. The other approach is to create a point of sale indicator and rely on pharmacy invoices and data. The department is recommending moving forward with the second option. A question was raised as to how this will impact a consumer’s ability to get a drug. Mr. Amick indicated it would have absolutely no impact and is more of a technical, backend change. 

Covered Outpatient Drugs

Medicaid Class-Specific  MCO Carve-Out