Bulk Rx Purchase

OPPOSE
S. 323/Golden
A. 3848/Gottfried

PSSNY's Bulk Rx Purchase Memo of Opposition

Fusing public and private prescription benefit programs funded by public dollars under a 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 lost revenues from rebates 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 the 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 Medicare 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 high price in the quality of patient care.

From the perspective of the state's community pharmacies, such a program would essentially level reimbursement across-the-board to Medicaid rates or lower. Community pharmacy would become a utility and at the mercy of political pressure to reduce reimbursements by the paying public without the benefit of annual reimbursement reviews and adjustments. With a single stroke of an administrator's pen, every community pharmacy would have its payment rate set for what could potentially be the lion's share of its business. With this same stroke of a pen, hundreds of smaller community pharmacies could be put out of business because they cannot remain open with the reimbursement rate offered. This would cause a significant loss of pharmacy access in our rural parts of the state.

For these reasons, the Pharmacist Society of the State of New York opposes this legislation.