Sept 2 -- The Centers for Medicare & Medicaid Services (CMS), Department of Health and Human Services (HHS), invites public comment to OMB by October 4, 2021 on the proposed renewal of the Survey of Retail Prices.
This information collection request provides for a survey of the average acquisition costs of all covered outpatient drugs purchased by retail community pharmacies. CMS may contract with a vendor to conduct monthly surveys of retail prices for covered outpatient drugs. Such prices represent a nationwide average of consumer purchase prices, net of discounts and rebates. The contractor shall provide notification when a drug product becomes generally available and that the contract include such terms and conditions as the Secretary shall specify, including a requirement that the vendor monitor the marketplace.
CMS has developed a National Average Drug Acquisition Cost (NADAC) for states to consider when developing reimbursement methodology. The NADAC is a pricing benchmark that is based on the national average costs that pharmacies pay to acquire Medicaid covered outpatient drugs. This pricing benchmark is based on drug acquisition costs collected directly from pharmacies through a nationwide survey process. This survey is conducted on a monthly basis to ensure that the NADAC reference file remains current and up-to-date. Form Number: CMS-10241; Frequency: Monthly; Affected Public: Private sector (Business or other for-profits); Number of Respondents: 72,000.
Since the inception of monthly surveying of retail community pharmacies for covered outpatient drug acquisition pricing, CMS has consistently been receiving a statistically significant number of responses monthly. The verified survey data has generated a publically-available pricing database entitled the National Average Drug Acquisition Cost (NADAC) file. The files are updated both weekly and monthly at
https://www.medicaid.gov/medicaid/prescription-drugs/pharmacy-pricing/index.html. Approximately 93%-97% of all covered outpatient drugs have pricing available on this file and most states are now using this file for their pharmacy reimbursement methodologies.
The methodology for the NADAC file, which reviews the data quality requirements, as well as the full description of the file, is also publicly available at
https://www.medicaid.gov/medicaid-chip-program-information/by-topics/prescription-drugs/ful-nadac-downloads/nadacmethodology.pdf.
Section 1902(a)(30)(A) of the Act requires, in part, that states have methods and procedures to assure that payment for Medicaid care and services is consistent with efficiency, economy, and quality of care. In accordance with these provisions and in light of the OIG reports concerning published prices, we believe it is necessary for states to have a more accurate reference price to base reimbursement for prescription drugs.
The data will provide information which CMS expects to use to assure compliance with Federal requirements. Section 1927(f) provides, in part, that CMS may contract with a vendor to conduct monthly surveys of retail prices for covered outpatient drugs. The statute provides that such prices represent a nationwide average of consumer purchase prices, net of discounts and rebates. The statute further contemplates that the contractor provide notification when a drug product becomes generally available and that the contract include such terms and conditions as the Secretary shall specify, including a requirement that the vendor monitor the marketplace. We have included terms in our vendor contract to obtain additional information regarding marketplace prices (including pharmacy prices), which would be provided on a voluntary basis.
CMS is publicly providing the National Average Drug Acquisition Cost (NADAC) files for states to consider when developing an Actual Acquisition Cost (AAC) reimbursement methodology. The NADAC is a pricing benchmark that is based on the national average costs that pharmacies pay to acquire Medicaid covered outpatient drugs. This pricing benchmark is based on drug acquisition costs collected directly from pharmacies through a nationwide survey process. This survey is conducted on a monthly basis to ensure that the NADAC reference file remains current and up-to-date. Currently 46 states rely on the NADAC pricing files for their reimbursement rates to pharmacy providers for covered outpatient drugs.
We propose to expand the number of retail community pharmacies that are sent the survey request each month. Currently, 2,500 pharmacies are randomly drawn each month and have the option of voluntarily completing the survey request. To further expand the survey population to derive more responses each month and ensure statistical validity to the NADAC pricing file, we propose to expand the survey population to up to 6,000 retail community pharmacies surveyed each month. This would remain a voluntary survey for completion.
Myers & Stauffer, LC was awarded a contract on July 8, 2021 to perform a “Survey of Retail Prices.” Myers & Stauffer will be utilizing David Bivin, Ph.D. to serve as the lead statistician for this project. Dr. Bivin is a Professor of Economics at Indiana University.
CMS Pharmacy Pricing webpage:
https://www.medicaid.gov/medicaid/prescription-drugs/pharmacy-pricing/index.html
CMS submission to OMB:
https://www.reginfo.gov/public/do/PRAViewICR?ref_nbr=202109-0938-001 Click on IC List for survey instrument, View Supporting Statement for technical documentation. Submit comments to OMB via this webpage.
FR notice inviting public comment -- item #1 in
https://www.federalregister.gov/documents/2021/09/02/2021-19012/agency-information-collection-activities-submission-for-omb-review-comment-request
Point of contact: Lisa Shochet, CMS 410-786-5445 Lisa.Shochet@cms.hhs.gov
For AEA members submitting comments to OMB, "A Primer on How to Respond to Calls for Comment on Federal Data Collections" is available at
https://www.aeaweb.org/content/file?id=5806