Bulk Rx Purchase Opposition Memo

Fusing prescription benefit programs funded by public dollars under central public authority creates a mega-state-administered program with some potential for benefit as well as for harm. The presumed benefit would be an increase in rebate dollars, but there is no guarantee of access to as broad an array of pharmaceutical products as are currently available. Nor is there any way to assure that manufacturer prices would not increase to accommodate the rebate burden in this or any private prescription benefit programs that operate in the state. In fact, such a rebate-heavy program with its cost of administration may drive up the overall cost of prescription drugs.

The intent of this legislation is laudable, but we question the implicit trust that the mega-administrator would conduct the program in an open and fair-minded manner relative to prior authorization requests. Recent experiences with the Part D plans should give us pause. Surveys of medical directors in skilled nursing facilities indicate that the systems for approving non-preferred drugs for patients who need them are either cumbersome or unavailable. In other words, too much emphasis on the bottom-line exacts a price in the quality of patient care. Will we throw the baby out with the bathwater?

From the perspective of the state's community pharmacies, such a program would essentially level reimbursement across-the-board to Medicaid rates or lower. With one stroke of the administrator's pen, every pharmacy in the state would have its payment rate set for a significant percentage of the prescriptions it fills. Pharmacies would become a defacto public utility operating at the mercy of rates set by a board of public officials and their perceptions as to the costs of running a pharmacy and out of the hands of pharmacy owners who know the cost of managing a pharmacy. Moreover, one preferred drug list for a very significant percentage of New Yorkers removes the incentive for a local pharmacy to have a broad inventory of drug products. Today pharmacies stock inventories designed to meet a variety of individualized and specific patient needs prescribed by physicians who know their patients well. Physicians who have stabilized their patients on a particular regimen of medications are often reluctant to change even one medication. Pharmacies, for a variety of sound clinical reasons, are able to fill prescriptions from their substantial inventory without delay. We should not lose sight of the fact that access to medications and the medications themselves are powerful tools to hold down healthcare costs overall. We continue to stand in opposition.