NCPA addresses adverse consequences regarding latest FUL guidance

ARLINGTON, Va. — The National Community Pharmacists Association on Monday drafted a letter to the Center for Medicaid and CHIP Services regarding the latest federal upper limit guidelines that the association characterizes as "getting worse with regard to the negative economic impact [to community pharmacies], not better."

"As we have communicated to you with all the lists that have been released, the implementation of these lists will be economically devastating for independent community pharmacies," the letter opens. "That means that patient care will suffer if access to pharmacy services is decreased because pharmacies have to close or shorten their hours."

According to NCPA's evaluation, the total number of products with a FUL increased from 935 to 959 between January and February, while the percentage of products with a FUL below a small independent community pharmacy’s actual acquisition cost increased from 40% to 40.6% of all products. For those products with a FUL above AAC, the average gain increased from 41 cents per product to 42.6 cents per product, but the average loss for products with a FUL below AAC increased from 30 cents to 31.4 cents per product.

The average loss per product has increased steadily between July 2011 and February 2012, NCPA stated. "The loss of these revenues would be devastating for independent pharmacies that disproportionately rely on Medicaid revenues and serve Medicaid patients. Moreover, in analyzing the FULs of some of the top Medicaid multiple-source drugs, it is clear that there continues to be rampant volatility in the FULs from month to month, and significant losses to pharmacies on some popular products," the association noted.

NCPA recommends to the agency that a final regulation be issued "so all parties know how to calculate [the average manufacturer price], collect several months of data to calculate draft FULs based on the final regulation and then determine whether such volatility remains in the calculations after all players know the 'rules of the road.'"

For a PDF of the letter, click here.