NACDS sends letter to super committee on patient health strategies related to diabetes care

ALEXANDRIA, Va. — In a letter to the congressional Joint Select Committee on Deficit Reduction, also known as the super committee, the National Association of Chain Drug Stores provided recommendations related to diabetes testing supplies for Medicare patients. NACDS said its recommendations would prevent the unintended consequences of hasty policy mistakes, and foster better and more cost-effective patient care.

"We understand the Joint Select Committee on Deficit Reduction must make difficult choices in order to find savings and rein in spending. However, we are concerned that the committee may consider changes that would impact access to diabetes testing supplies (DTS) for Medicare beneficiaries," NACDS wrote to Sen. Patty Murray, D-Wash., and Rep. Jeb Hensarling, R-Texas.

NACDS urged the super committee to resist limiting access to DTS in a way that will lead to poorer health outcomes and escalating costs of care. NACDS specifically cautioned against moving any segment of retail pharmacy into the Medicare competitive bidding program and against reducing reimbursement for diabetes testing supplies obtained at a retail pharmacy to below-cost levels.

Rather, NACDS emphasized the preventive services that patients with diabetes encounter in their retail pharmacies, and encouraged the consideration of alternative approaches, such as moving coverage of diabetes testing supplies from Medicare Part B to Part D, which would produce program savings without compromising beneficiary access and health.

While diabetes testing supplies are considered DME under the Medicare program, the Centers for Medicare and Medicaid Services has excluded diabetes testing supplies furnished by retail pharmacies from competitive bidding — a move that NACDS hails as "intentional and wise" and vital for "ensuring beneficiary access to these vital supplies."

"Without this exclusion, it is highly unlikely that retail pharmacies would be able to furnish DTS in Medicare, since competitive bidding reimbursement rates are below DTS product costs for retail pharmacies," NACDS explained in the letter. "Chain pharmacies, which make up 66% of retail community pharmacies, are a vital access point for both diabetes testing supplies and prescription medications. Maintaining access to diabetes testing supplies at local pharmacies allows seniors to access to all of the equipment and prescription drugs they need to manage their disease from a single source."

NACDS said in the letter that reducing reimbursement to retail pharmacy also would result in counter-productive consequences. NACDS said below-cost reimbursement cuts would "hurt access to care and severely limit the valuable role of pharmacist-patient interactions in reducing overall program spending."

"Reduced access and the elimination of face-to-face pharmacist counseling will lead to under-testing, decreased medication adherence, poorer outcomes, and increased overall costs," NACDS wrote.

To further capitalize on cost-saving opportunities, NACDS recommended moving diabetes-testing supplies from Medicare Part B to the Part D program. "Prescription drugs related to diabetes, such as insulin, are provided to Medicare beneficiaries through Part D," NACDS explained. "However, durable medical equipment such as diabetes monitors, testing strips and lancets are provided to Medicare beneficiaries through Part B. This results in difficulties coordinating care."

"Diabetes supplies should be covered through the Part D benefit," NACDS urged. "This would mirror commercial practices, would allow beneficiaries with diabetes to access necessary medications and supplies from the same provider if they chose, and would reduce costs by moving products to the more efficient Part D program, which continues to operate below Congressional Budget Office projections.  Conversely, proposals to expand the competitive bidding program to include retail pharmacy-provided diabetes testing supplies are inherently flawed, as they fail to take into account that fragmenting care for Medicare beneficiaries with diabetes will inevitably result in increased costs."

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