NACDS responds to proposed CMS repeal of access rule

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NACDS responds to proposed CMS repeal of access rule

09/18/2019
The National Association of Chain Drug Stores shared comments with the Centers for Medicare and Medicaid Services regarding a proposed rule the trade organization contends will jeopardize patient health and increase costs.

The proposed rule would repeal the approach that states use to demonstrate and ensure compliance with federal access requirements, which require Medicaid patients to have access to healthcare services at least on par with those available to a geographic area’s general population.

“CMS must maintain a standardized, transparent process for states to determine if they are meeting federal access requirements,” NACDS president and CEO Steve Anderson wrote in the comments. NACDS said that its concerns include the importance of network adequacy for Medicaid patients, with Anderson noting, “any changes to state requirements to demonstrate compliance with access standards should include policies to ensure that patients will continue to have access to their current providers and pharmacies of choice.”

Access is critical to ensuring high-quality patient care and keeping costs down, Anderson said.

“Restricting provider networks result in restricted patient ability to access their healthcare providers and unnecessary disruptions in needed care,” he said. “As a result, there is the potential for increased overall healthcare expenditures due to the use of more costly healthcare services among Medicaid patients.”

NACDS’ comments also discussed the value of pharmacy in state Medicaid programs, including the fact that ensuring pharmacy access helps lower state cost. The comments highlight the relationship between pharmacy access and medication adherence, and discussed the value of such pharmacy services as vaccinations, health education, point-of-care and disease state testing, disease management and medication synchronization.

“Pharmacists are even more highly valued by those that rely on them most — older Americans, individuals managing chronic diseases, and those in urban, rural and underserved areas. Pharmacy services improve quality of life and healthcare affordability,” NACDS’ comments said.

Besides the impact the proposed rule would have on patient care, NACDS highlighted that the proposal violates rules governing the policymaking process. It noted that the proposed rule does not meet Administrative Procedure Act requirements that an agency provide a reasoned explanation that meets specific qualifications.

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