NACDS to HHS inspector general: Pharmacies are essential to value-based care

The National Association of Chain Drug Stores is making its case for the value of pharmacy and its role in patient care to the Department of Health and Human Services' Office of the Inspector General. The Arlington, Va.-based trade group has submitted comments to the agency, which will decide whether pharmacies should be included in the definition of “value-based enterprise, or VBE participant.”

In a proposed rule, the OIG invited feedback as to whether pharmacies should be excluded from the definition of a VBE participant.

The decision is being made on one specific point of regulatory policy that relates to the Anti-Kickback Statute, and its safe harbor provisions that apply to providers that are instrumental in care coordination, rather than to those that primarily provide items. NACDS is arguing that exclusion from the definition would create a needless barrier to pharmacy patient care.

“Community pharmacies can and do play a critical role in coordinating and managing care for patients. As evidenced throughout our comments, community pharmacies should be included in the definition of ‘VBE participant.’ We urge OIG to remedy this misconception in the final rule,” NACDS president and CEO Steve Anderson wrote in the comments.

“As you work through the HHS ‘Regulatory Sprint to Care’ to improve patient outcomes, produce health system efficiencies, lower costs, and transform our nation’s healthcare system to better pay for value, we urge you to consider how community pharmacies are helping to accelerate your efforts. Moreover, we urge you to consider how community pharmacies could further accelerate your efforts through recognition in the proposed rule,” he wrote.

NACDS’ comments describe specific examples in which payers have recognized the value of pharmacy to improve quality and value, and incentivized pharmacies to deliver clinical care outside of dispensing prescriptions.

NACDS said its advocacy on this issue is part of its proactive campaign to enhance patients’ access to health and wellness services.