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T/F: outpatient US drug expenditures are stable as a percent of national health expenditures
true
Overall health care expenditures increased ____% from 2023 to 2024
7.2%
Name three reasons for disconnect between newspaper stories about high drug prices and actual drug expenditures
1. list price vs. net price and the role of manufacturer rebates/discounts
2. most prescription drugs used are lower-cost generic drugs
3. high patient out of pocket costs for outpatient prescription drugs
Describe the manufacturer rebate process
1. manufacturer and PBM negotiate rebate amount
2. PBM and employer negotiate amount passed through to employer
3. at the end of the quarter, manufacturer pays PBM agreed upon rebate for every prescription used by employees of contracted employer
4. PBM passes the rebate through to employer/health plan
T/F: net prices and manufacturer rebate amounts are typically available to the public
false - typically only list prices
Which payers get more rebates?
payers who are willing to have more restrictive formularies
For which types of medications are rebates typically given
brand name drugs with close substituents
______ requires rebates for generic drugs
Medicaid
Describe two emerging models based on lower list prices for medications as a transition away from the rebate model
1. lower list price for everyone with reduced rebates
2. lower list price for some - direct to consumer cash sales, convoluted workarounds, government intervention
Rationale for movement away from the rebate model
- public pressure to lower drug prices
- government intervention (Inflation Reduction Act of 2022)
- PBM's gaining negative publicity and legislation against
New requirement based on FTC Enforcement Action/Express-Scripts FTC settlement
must provide a standard offering to plan sponsors that ensures members' out-of-pocket expenses are based on the drug's net cost, rather than artificially inflated list price
What did the Inflation Reduction Act of 2022 require?
the federal government to negotiate Medicare drug prices for some high-cost single source brand name drugs
Negotiated "Maximum Fair Prices" are only for people enrolled in _________
Medicare
Implementation timeline of the Prescription Drug Provisions in the Inflation Reduction Act
2025 - $2,000 out of pocket max and implementation of Medicare Prescription Payment Plan (MPPP)
2026 - 10 Part D drugs
2027 - 15 Part D drugs
2028 - 15 Part B and D drugss
2029 - 20 Part B and D drugs
Drug selection criteria for Medicare Drug Price Negotiation
1. among top 50 drugs by gross Medicare spending
2. single source brand name drug or biological product without approved and marketed therapeutic equivalents
3. at least 7 years for brand name or 11 years for biologics past FDA approval date (longer now)
Factors considered when determining negotiated MFP
- manufacturer's R & D costs and extent to which they have recouped those costs
- production costs
- federal support for R & D related to drug
- clinical benefit of the drug and extent to which the drug represents a therapeutic advance compared to alternatives
Potential effects of Medicare negotiation drug prices
- change in patient OOP costs?
- change in manufacturer R&D strategies
- change in Medicare part B and D premiums
- change in pricing and marketing strategies
- spillover effects to list prices and rebates for other payers like private insurers
- effects on pharmacies
Describe how discount cards work
- based on idea that pharmacy usual and customary prices are higher than PBM's pharmacy reimbursement rates
- discount card company contracts with PBMs to give patients access to the PBM reimbursement rates at participating pharmacies
- GoodRx displays the lowest PBM reimbursement amount at each pharmacy
- patient take coupon to their pharmacy where they pay the coupon price, rathe than the pharmacy's usual and customary price
- the pharmacy processes the prescription through the PBM specified on the coupon and charges the patient the listed coupon price
Which patients use discount cards the most?
cash paying patients, but also used by patients with private and public insurance
How do discount cards impact pharmacies?
- instead of getting paid their usual and customary prices for a cash prescription, pharmacies receive the lower PBM reimbursement rate price
- when the pharmacy processes the prescription, they pay a transaction fee that is split between the discount card and PBM
- to be in a PBM's network, pharmacies may be required to accept all discount cards that PBMs participate in
Describe how Mark Cuban CostPlus Drug Company works
- online mail order pharmacy
- contracts to but mostly generic drugs from manufacturers and sell them to consumers on their website using a transparent pricing model
- contract with another company to ship the prescription drugs to the patient
- also started a discount care type program that can be used at local pharmacies
- opened a generic pharmaceutical manufacturing facility to target shortage medications
Original goal of 340B
give organizations that serve low-income patients access to discounted prices for prescription drugs
Describe how 340B works
1. provider at a 340B entity writes a prescription
2. 340B entity or 340B contract pharmacy buys drugs at 340B discounted price and dispenses the 340B prescription
3. the payer is billed for dispensed prescription at regular prices
4. profit is split between the 340B entity and 340B contract pharmacy
T/F: 340B eligibility is based on patient income and/or insurance
false - dependent on provider eligibility
Describe 340B pricing
- drug prices are required to be below the Medicaid ceiling price
- minimum discount of 23.1% of the Average Manufacturer Price (AMP)
- discounts may be as high as 70-100%
- 100% discounts fall under the penny rule and are priced at $0.01
T/F: 340B drugs are not eligible for rebates
true
Major concerns with the 340B program
- 340B entities receive and keep 340B discounts for privately insured and Medicare patients
- 340B entities are not required to pass along discounts to low income or uninsured patients
- 340B entities are not required to spend 340B profits on care for indigent patients
Define assests
resources owned by the pharmacy
Define liabilities
resources owed by the pharmacy
Define Owner's equity or net worth
money remaining after liabilities are subtracted from assests
Define revenue
money earned by the pharmacy for services rendered or products sold (sales)
Define expenses
costs incurred to generate the pharmacy's revenue
Define Cost of Goods Sold (COGS)
money spent for products sold by the pharmacy
Define Operating Expenses
money spent to acquire resources used by the pharmacy
Define net income/profit
money left after expenses are subtracted from revenue
Defien balance sheet
shows the financial condition of the pharmacy at a single point in time
Define income statement
shows a summary of the pharmacy operations for a period of time (also called Revenue and expense statement or profit and loss statement)
Owner's equity equation
assets-liabilities
Current ratio equation
current assets/current liabilities
Quick ratio equation
(Current assets - inventories)/current liabilities
Gross margin percent equation
(sales - COGS)/sales * 100
Net profit percent equation
net profit/net sales * 100
Gross margin/profit equation
sales - COGS
Net profit/income equation
sales - COGS - operating expenses
Name the two biggest pharmacy expenses
costs of goods sold
labor
Three main functions of supply chain management
demand planning
inventory management
procurement
Define demand planning
reliably forecasting what drug products will be sold
Define inventory management
minimizing financial investment while maintaining adequate supply of drug products
Define procurement
purchasing and sourcing of drug products
The drug product supply is regulated by the _______________ Act
Drug Supply Chain Security Act
Flow of the drug product supply chain to patients
API > pharmaceutical manufacturers > drug wholesalers/suppliers > hospitals or pharmacies > patient
What is the goal of DSCSA?
protect consumers from counterfeit, stolen, and contaminated drugs by ensuring that the origin of all products can be tracked throughout the entire drug supply chain
US suppliers provide only ____% of API for US prescriptions
12%
Describe the newly implemented tariffs incentivizing onshoring of the drug supply chain
applies to APIs and finished pharmaceutical products
imposes 100% tariffs on brand name pharmaceutical manufacturers with the following exceptions
- have most favored nation pricing deals
- have previously negotiated trade deals
- agree to build manufacturing or other facilities in the US
- orphan and some specialty drugs may be exempt
Costs associated with insufficient drug product inventory
- lost business
- patient dissatisfaction
- higher procurement costs
Examples of inventory "carrying costs"
- capital costs - money that could be used elsewhere
- storage costs - space to store inventory
- cost of risk
Define inventory turnover ratio
number of times a pharmacy's inventory is replaced over some period of time
Inventory turnover ratio equation
COGS/average inventory
Recommended inventory turnover ratio
15-20
Issues/challenges related to inventory management
- high cost of specialty drugs
- shortages
- third party reimbursement delays
- drug price increases or decreases
- formulary changes
- low margins on third party prescriptions
Big 3 primary drug wholesalers
McKesson
CardinalHealth
Cencora
Examples of secondary drug wholesalers
TopRx
Anda
Apital Drug
Republic pharmaceuticals
KeySource
Tri-Pharma
What are Group Purchasing Organizations (GPOs)?
intermediaries between the pharmacy and drug wholesaler
- may negotiate purchasing terms with wholesalers
Cost of dispensing (COD) includes all costs of filling a prescription except the cost of ________________
the drug product (COGS)
What is the largest component of cost of dispensing?
labor costs
Define direct costs
costs that are completely attributable to one output (ex. prescription vials and labels)
Define indirect costs
costs that are associated with multiple outputs (ex. rent)
Define pharmacy fixed costs
costs that do not change as the pharmacy volume changes (ex. rent)
Define pharmacy variable costs
costs that change directly as the volume of services increases
Define economies of scale
the cost per unit decreases as volume increases
Describe the process for calculating cost of services
1. identify and allocate all costs associated with performing the service
2. sum up all these costs
3. divide the total costs by the appropriate unit of use over a selected time period
4. gives you the average cost per unit
_______ costs are allocated 100%
direct
Three methods for allocating indirect costs
Percent of sales - % of total sales generated by the service of interest
Square footage - % of space used by the service of interest, typically for expenses like rent and utilities
Percent of time - % of time spent on the service of interest and multiply by the salary or multiply staff hours spent by hourly wage
Uses for cost of service information
- analyze cost trends over time
- set prices for services
- determine profitability of services
- evaluate third party reimbursement
- justify services
- aid in cost cutting decisions
- aid in personnel decisions
Key reasons that an imbalance of market power between third party payers and pharmacies has made dispensing prescriptions less profitable
1. PBM market concentration/high market share
2. growing vertical integration
What is the main role of pharmacy services administrative organizations (PSAOs)?
- negotiate and sign contracts between pharmacy and third-party payers
- provide pharmacies with information and tools to help improve their performance on measures used for value-based reimburseemnt
Third-party contracts typically reimburse at the lower of ____________ or ____________
the pharmacy's usual and customary price or the reimbursement formula price
Third parties pay the pharmacy the contractual reimbursement amount minus any ____________________
patient cost sharing
What does it mean for pharmacies to accept assignment?
not charge the patient more than the specified cost-sharing amount
Two components of third-party reimbursement formulas
ingredient cost + dispensing fee
Define actual acquisition cost (ACC)
the pharmacy's cost to purchase the drug product
Define estimated acquisition cost (EAC)
third-party estimate of AAC in which reimbursement is based on
Four methods third-parties use to calculate EAC
Average Wholesale Price (AWP)
Wholesale Acquisition Cost (WAC)
Average Acquisition Cost (AvAC)
Maximum Allowable Cost (MAC)
Define average wholesale price (AWP)
a list price for what drug wholesalers charge pharmacies (not what the pharmacy actually pays)
Typical equation used to estimate EAC based on AWP
EAC = AWP - some percent
(AWP is higher than AAC, so third-parties adjust estimate)
Define wholesale acquisition cost (WAC)
a list price of what drug wholesalers pay to buy drug products from manufacturers
T/F: wholesalers pay manufacturers less than WAC
true
Define average acquisition cost (AvAC)
an average of AACs from multiple pharmacies
How is AvAC typically determined?
determined by surveys asking pharmacies to report their actual acquisition costs (AAC)
Define National Average Drug Acquisition Cost (NADAC)
a measure of AvAC that is published by the federal government
How is NADAC typically determined?
voluntary monthly surveys of random sample of pharmacies in all states to determine AACs (excludes discounts or rebates)
State Medicaid programs generally use ________ to determine pharmacy reimbursement
NADAC
Define Maximum Allowable Cost (MAC)
the highest amount that a third-party will pay for a multi-source drug product
What is the name of the federal maximum allowable cost list?
Federal Upper Limit (FUL)
State Medicaid programs may use the FUL or create their own ______________
state maximum allowable cost list (SMAC)
Ingredient cost spread equation
EAC - AAC
Private third-party plans often have dispensing fees as low as ____ to ____
10-50 cents
Why may 90-day supplies decrease pharmacy reimbursement?
only get 1 dispensing fee instead of 3 if they were to get 30 day supply at a time
Dispensing fees need to be higher for an EAC based on ___________, compared to an EAC based on _______ or _______
higher for AvAC compared to AWP or WAC
What is another name for AAC?
cost of goods sold (COGS)