Investor Presentaiton
August 16, 2023
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pharmacy benefit for Medicaid recipients. OHA has heard favorable patient and
practitioner feedback around creating a single PDL and uniform PA criteria for all Medicaid
recipients. OHA would like to better understand what is envisioned with recommendation
#5, "Implement a fair and uniform reimbursement policy for CCOS," as this could mean
various things to different readers. One such uniform reimbursement policy could be a
single PBM, which could bring uniform reimbursement to pharmacies. However, policies
such as requiring minimum dispensing fees and designating critical access pharmacies
could be interpreted as addressing fair reimbursement as well as sustaining access to
pharmacy services.
Additionally, with respect to recommendation #9, “Study if the creation of a state
prescription drug purchasing program would save tax-payer dollars," OHA suggests
exploring the Oregon Prescription Drug Program (OPDP)/ArrayRx as a possible PBM
model and/or solution for Medicaid coordinated care programs. The OPDP/ArrayRx
Steering Committee members have collectively over 150 years of pharmacy experience
and the program has a 20-year history of cost savings. Via an interstate cooperative
agreement, Oregon, Washington, Nevada and soon, Connecticut utilize OPDP/ArrayRx to
effectively leverage all participating programs' purchasing power. Rolling Medicaid
managed care PBM services into OPDP/ArrayRx would effectively double this program's
current purchasing power and, in turn, reduce the administrative costs for Oregon and the
other interstate cooperative members.
Finally, recommendation #3 recommends exploring reverse auctions. These are costly, as
a vendor must first be selected to conduct the auction, and it is likely that PBMs would
reduce payment to pharmacies to make their reverse auction bid work. This, in turn, would
worsen the pharmacy access issues Oregon is currently experiencing. Further, reverse
auctions do not abide by Oregon procurement statutes and rules and would violate specific
procurement requirements. Conversely, OPDP/ArrayRx has demonstrated savings and
effectiveness within the state over the past 20 years, whereas reverse auctions do not
have this long-standing history.
Below is our detailed response to each OHA recommendation in the audit.
RECOMMENDATION 1
Expand contract provisions to more proactively monitor and enforce contract
compliance and further develop monitoring processes that will give OHA reasonable
assurance CCOS and PBMs are in compliance. Consider the following:
.
•
Require CCOs to obtain a yearly independent audit of their PBM for high-risk
areas. An independent audit could help give OHA reasonable assurance that
CCOs and their PBMs are in compliance. Note that a yearly audit should not
replace a CCO's responsibility for on-going monitoring.
Incorporate monitoring results into the contracting process to improve oversight
and program outcomes.
Update the CCO contract to apply the review requirement to all CCO-PBM
amendments.
• Require PBM contracts to be pass-through.View entire presentation