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Information Sharing

  • The Administration released the notice of proposed payment and benefit last week
  • It is also expected that they will release an overarching transparency rule soon
  • The Administration is looking to increase patient access to their health information through Blue Button, RTPBC, and drug supply,  but we expect the Administration announcement will include transparency for other areas that have not been previously discussed
  • It is anticipated that these announcements are the start of additional regulations that will require more transparency from players throughout the health care ecosystem


Drug Price Transparency

  • Recent legislative changes to the pharmacy gag rule have now made the cash price of prescriptions available to beneficiaries
  • Two challenges to this change are that no records are kept or sent to the provider to show if a beneficiary paid out of pocket for a prescription and it paying out of pocket doesn’t count towards your true OOP
  • It was suggested that a system could be implemented to enable this information be sent back to the provider for tracking so that they know that the patient filled the prescription, which will enable the provider to better manage the beneficiary’s care
  • Another benefit of enabling this data exchange is that it may improve providers scores and ratings as the beneficiary feels more satisfied by their care as they got the best deal possible
  • There was also some interest in opening up the plan finder to create a central database


Review of the Comment letter

  • CARIN is working to make the cash price known, which is a benefit to the patient and provider
  • For  drugs that do not have alternatives, members discussed the option of directing patients to the lowest cost pharmacy within a 3 mile radius
    • One challenge is that the price information comes from the plan which may not have access to the most up to date pharmacy price
  • A revised comment letter will be sent to members for review prior to submission by the 25th
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