ORAP UPDATE Pharmacy Benefit Managers, Collections, PRC Rates and GAO

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Presentation transcript:

ORAP UPDATE Pharmacy Benefit Managers, Collections, PRC Rates and GAO Terri Schmidt Acting Director, Office of Resource Access and Partnerships October 24,2017

Pharmacy Benefit Manager (PBM) Update  BACKGROUND - TSGAC requested IHS to provide assistance in resolving denials and non-payment from PBMs and Private Insurance collections DHHS reached out to CVS/Caremark CVS/Caremark verbally agreed to identify a point of Contact for Tribes/Tribal Organizations operating under and ISDEAA agreement with IHS Claims submission process Dear Tribal Leader Letter/Dear Urban Leader Letter Outline process Provide CVS/Caremark contact information Depart. Reached out to one of the larger PBM’s and initiated discussions about these issues with representatives from CVS/Caremark’s HQ Several discussions were required for CVS/Caremark to gain an understanding of the statutory right to recovery under 1621e Earlier this month (October 2017) CVS/Caremark notified IHS they would like to discuss logistics to make sure that payments are being made accordingly to 1621e. They have verbally agreed to identify an internal POC for Tribes and Tos operating under an ISDEAA agreement with IHS, to discuss specific claims submission process with CVS/Caremark Indian Health Service / Office of Resource Access and Partnerships

PRC RATE PRC Rate regulation located at 42 CFR 136 Subpart I. Gives I/T/U’s the ability to cap payment rates to physicians and non-hospital providers and suppliers. Mandatory for IHS and Tribes can opt-in I/T/U’s can negotiate a higher rate of payment with providers Must meet a reasonable pricing arrangement Most Favored Customer Rate is a platform for negotiation I/T/U’s are responsible for rate calculations Payment amount is provider specific Indian Health Service / Office of Resource Access and Partnerships

PRC RATES In the absence of a contract or agreement with IHS or Tribes that have opt-in for a negotiated rate. The PRC Rate applies as follows When a Provider accepts a referral/request for services from an I/T/U When a Provider accepts a purchase order for services from an I/T/U When a Provider files a claim for payment When a Provider accepts payment In these instances the Provider cannot balance bill the patient Indian Health Service / Office of Resource Access and Partnerships

PRC SAVINGS Currently all IHS Areas and 9 Tribes have opted-in 5 of the Tribes use the FI Savings as of August 31, 2017 for IHS and Tribes that use the FI $221,751,836 Million Indian Health Service / Office of Resource Access and Partnerships

PRC/GAO Directors Workgroup on Improving PRC October 31 and November 1 GAO will meet with the Workgroup GAO recommendations PRC distribution methodology Indian Health Service / Office of Resource Access and Partnerships