WOONSOCKET, R.I., July 16, 2018 /PRNewswire/ -- CVS Health
(NYSE: CVS) today submitted its comments in response to the Request
for Information (RFI) on the Trump Administration's Blueprint to
Lower Drug Prices. In a cover letter to Secretary of Health
and Human Services (HHS) Alex Azar
summarizing the full comments submitted to HHS, the company
underscored support for the Administration's goals and emphasized
the industry-leading steps it has taken to hold down drug costs and
bring innovative solutions to market to help consumers.
"Until drug manufacturers reduce the high price they set for
these drugs, we know this problem is not going away," the company
said in the letter. "We support the Administration's goal to lower
drug prices and reduce out-of-pocket costs for consumers and we are
using every innovative tool possible to bring down the cost of
drugs ourselves."
The full text of CVS Health's cover letter to Secretary Azar
follows here:
Secretary Alex M. Azar II
Department of Health and Human Services
200 Independence Ave. SW, Room 600E
Washington, DC 20201
Re: Response to the Health and Human Services Blueprint
to Lower Drug Prices and Reduce Out-of-Pocket
Costs
Dear Secretary Azar:
CVS Health appreciates the opportunity to comment on the request
for information included in the Health and Human Services (HHS)
Blueprint to Lower Drug Prices and Reduce Out-of-Pocket Costs
published in the Federal Register, vol. 83, no. 95
(May 16, 2018).
CVS Health is a pharmacy innovation company helping people on
their path to better health. Caremark, our pharmacy benefit
manager (PBM) company, provides services to plans covering 12
million Medicare Part D beneficiaries, including SilverScript, our
national Medicare Part D plan, which covers approximately 6 million
beneficiaries. Through our more than 9,800 retail pharmacies,
more than 1,100 walk-in medical clinics, dedicated senior pharmacy
care business servicing more than one million patients per year,
and expanding specialty pharmacy services, we enable people,
businesses, and communities to manage health care in a more
affordable, effective ways. Our unique integrated model
increases access to quality care, delivers better health outcomes,
and helps to lowers overall health care costs.
We see the impact rising drug prices have on our patients every
day. Our pharmacists witness the sticker shock first hand as
patients question the price of brand-name drugs, especially as
prices have grown 10 times faster than inflation over the last five
years. And until drug manufacturers reduce the high price
they set for these drugs, we know this problem is not going away.
We support the Administration's goal to lower drug prices and
reduce out-of-pocket costs for consumers and we are using every
innovative tool possible to bring down the cost of drugs
ourselves.
Throughout our response to this request for information (RFI),
it is clear that policy solutions that lower drug prices for health
plans and consumers and reduce out-of-pocket costs are aligned with
our goal of reducing healthcare costs and helping improve
healthcare outcomes. One of the key roles of government is to
provide a regulatory framework in which the private sector can
innovate and bring cost-saving solutions to the marketplace.
This means creating an environment that allows private sector tools
to be used more effectively. The government's vision for the
future should encourage modern tools and innovation from the
private sector and CVS Health is proud to be a leader in this
space.
As a pharmacy benefit manager, CVS Health negotiates the lowest
possible cost from drug manufacturers for our clients, which are
health plans, employers, unions, government programs like Medicare
Part D and Medicaid, and ultimately for the millions of Americans
who pick up their prescriptions at pharmacy counters every day.
Even in an environment where the list prices of drugs are
continually rising, we kept drug price growth at a minimal 0.2% in
2017, the lowest in five years, despite manufacturer brand list
prices increases on drugs near 10%. Further, over 30% of our
clients spent less per member in 2017 than they did in 2016 on
prescription drug costs. We return over 95% of rebates to
commercial clients and their members. For Medicare Part D
plans, effectively 100% of the rebates are passed through to help
lower premiums, which reduce costs for both the beneficiary and the
government. The tools used by pharmacy benefit managers to
remove costs from the health care system are projected to save
$654 billion on drug costs over the
next decade.1
Today, CVS Health provides availability of rebates at the
point-of-sale as an option for all clients. In addition to
helping consumers reduce out of pocket costs, this approach
demonstrates the true cause of rising drug prices for consumers,
which is the price set by pharmaceutical manufacturers. For
consumers in high deductible health plans, the availability of
point of sale rebates on their medications before their deductible
is met, can be a key solution to help consumers stay adherent on
their essential medications by making them affordable.
But we do not stop there. We are also using an innovative
technology solution to bring real-time benefits information to the
point of prescribing. Through their electronic health record
system, prescribers are able to see member-specific out of pocket
costs for a selected drug based on where they are at that moment in
their deductible and up to five lowest-cost clinically appropriate
therapeutic alternatives, specific to the member's formulary.
We have also brought this technology to the pharmacy
counter. Our nearly 30,000 pharmacists utilize the Rx Savings
Finder tool to quickly identify available savings opportunities
when beneficiaries present their prescriptions. This tool is
expected to produce an average of $420 in additional annual savings for the
patient.
Our pharmacists are committed to helping patients find the most
affordable options, and we ensure that pharmacists in our Caremark
networks do the same. Accordingly, CVS Health does not engage in
gag clauses, and we support efforts to ban them.
Despite our efforts to lower costs for consumers, we are working
within a system where competition has been stalled, which hurts the
consumer most. As you will see in our response, we believe
increasing market competition by making more generics available is
absolutely necessary to make a real impact. We are proud to
have offered a generic epinephrine auto-injector at the lowest cash
price in the market as a way to combat the exorbitant price
increases in the brand drug, EpiPen. We are pleased to see
the Food and Drug Administration's (FDA) efforts to speed approval
of generic drug applications and to prioritize review of drugs with
only one manufacturer to encourage competition. A fair
playing field is not just about generics though, we must expand the
use of biosimilars and eliminate the tactics that stall
competition.
While we have provided responses to many of the questions posed
in the RFI, there are four main areas we wish to highlight where
the Administration can take immediate steps to help reduce costs
for consumers. They include:
1)
With more Americans now covered through a high deductible health
plans with an associated health savings account (HSA), millions of
consumers are seeing higher-out-of-pocket costs on the part of the
benefit they use most—their prescription drug coverage—because they
often do not have full prescription coverage until they have met
their deductible. Under current Internal Revenue Service
guidance for HSAs, only certain preventive products and services
may be covered by a high deductible health plan prior to
satisfaction of the minimum deductible. We urge you to expand
coverage of preventive products and services to include products
for managing chronic conditions, or to allow a high deductible
health plan to cover drugs prior to satisfaction of the
deductible. This would help these plans provide more first
dollar coverage at the pharmacy counter, improve medication
adherence and health outcomes and reduce sticker shock when
consumers are filling their prescriptions. You can accomplish
this immediately through the regulatory or guidance
process.
2)
As mentioned above, we have seen great results from prescribers
accessing the real-time benefits information to the point of
prescribing. Through the electronic health records system,
providers are able to see the member-specific cost for a selected
drug, based on a member's coverage, along with alternative options
based on the patient's formulary. For prescriptions written
by physicians using real time benefits and filled by the member;
when a lower-cost preferred alternative is presented, physicians
are switching to the lower cost alternative 40% of the time.
In these cases the member cost was $130 lower per fill, compared to the original
non-preferred drug selected. Physicians who are using real
time benefits are switching to a covered drug 75% of the time when
the original drug is not covered. We would encourage the
Administration to use every regulatory tool at your disposal to
incentivize the adoption of point of prescribing real time benefit
information. This would save patients a significant amount of
money.
3)
Competition among brand drugs and generics are important in
lowering drug costs. The increasing use of biosimilars will
bring competition into biopharmaceutical market. The
Administration should seek to increase competition in the drug
marketplace through FDA's actions as soon as possible. More
must be done to make generics available, including expanding the
use of biosimilars, and eliminating tactics that stall
competition. To increase the availability of biosimilars, we
believe the Administration should support shortening the
exclusivity period for biologics from twelve to seven years, and
finalize interchangeability guidance, which is key to expanding
adoption of these lower cost alternatives. By prohibiting
pay-for-delay agreements, the Administration can curb
anti-competitive practices and help bring lower cost,
clinically-equivalent generic medications to market more
quickly. CVS Health also firmly supports the bipartisan
CREATES Act to stop the abuse of Risk Evaluation and Mitigation
Strategies, which costs the health care system $5.4 billion annually by keeping generics from
entering the market. We would encourage the Administration to
also support the CREATES Act.
4)
Finally, we support the Administration's proposals to strengthen
negotiating tools in Part D, including by providing greater
formulary flexibility, which will help build upon the program's
successful record of delivering affordable drug benefits to seniors
at a cost far less than originally projected.
We appreciate the opportunity to provide comments on the HHS
Blueprint, and we welcome opportunities to work with the
Administration to lower drug prices and reduce out-of-pocket costs
for consumers.
1 Visante Inc., "Pharmacy Benefit Managers
(PBMs): Generating Savings for Plan Sponsors and Consumers,"
Prepared for PCMA, February 2016,
https://www.pcmanet.org/wp-content/uploads/2016/08/visante-pbm-savings-feb-2016.pdf.
Media Contact:
Erin Shields
Britt, Corporate Communications
(401) 770-9237
Erin.Britt@CVSHealth.com
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