Investor Presentaiton

OREGON Appendix C: Interim Letters to the Legislature OREGON AUDITS DIVISION Cheryl Myers Deputy Secretary of State, Tribal Liaison Kip Memmott MA, CGAP, CRMA Audits Director September 14, 2022 Representative Nancy Nathanson Oregon Legislature 900 Court St. NE Salem, OR 97301 Dear Representative Nathanson: In response to your request, we are providing information about leading practices adopted in other states regarding pharmacy benefit managers (PBMs). This letter identifies potential opportunities for legislative action related to Oregon PBMs. States have implemented these practices in their Medicaid program or public employee health plans and are taking a varied approach in adopting PBM models. Each approach has different costs and benefits and there is no perfect solution. Health equity concerns Pharmacy closures have negatively impacted Oregon's rural and frontier communities. In addition, studies show pharmacy closures affect poor communities and disproportionately impact Black and Latino communities. Pharmacies are a critical element of health care and are important in promoting health outcomes for the people of Oregon. 2,3 Pharmacists are ideally positioned in their community to address gaps in care by collaborating with other health care providers, which can help eliminate health disparities. For these reasons, steps should be considered to protect Oregon pharmacies. 4 Pharmacy protections Pharmacy audits, regulations, and appeals PBMS regularly audit pharmacies to identify improper payments and verify the patient received the correct medication and dosage. There is a risk PBMS could abuse this process to recoup money from expensive prescriptions for minor administrative errors that do not harm the patient. Some states have 1 Guadamuz JS, Wilder JR, Mouslim MC, Zenk SN, Alexander GC, Qato DM. Fewer pharmacies in black and hispanic/latino neighborhoods compared with white or diverse neighborhoods, 2007-15. ² Qato DM, Alexander GC, Chakraborty A, Guadamuz JS, Jackson JW. Association Between Pharmacy Closures and Adherence to Cardiovascular Medications Among Older US Adults. 3 Hillier-Brown, F., Bambra, C., Thomson, K. et al. The effects of community pharmacy public health interventions on population health and health inequalities: a systematic review of reviews protocol. 4 Westberg SM, Sorensen TD. Pharmacy-related health disparities experienced by non-English-speaking patients: impact of pharmaceutical care. 255 Capitol St. NE Suite 180 Salem OR 97310 (503) 986-2255 sos.oregon.gov/audits

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