Jul
25

Physician dispensing in comp – two small victories

Yesterday the Illinois Workers Comp Commission voted in favor of a regulation that would tie reimbursement of physician dispensed drugs to the price set by the original manufacturer. While this regulation has to pass thru a legislative committee before it can be implemented, that was good news indeed for Illinois’ work comp claimants, employers, and taxpayers.
The meeting was well-attended, and included representatives from the insurance industry, health care providers, PBMs (yours truly and others) and industry trade groups.
Noticeably absent were the drug chains, including Walgreens. I’m at a loss to understand this, as the WCRI report released last week showed 62% of pharmacy costs in IL are from physician-dispensed drugs. Those patients are NOT going to their corner pharmacy if they are getting their meds from their docs.
When patients get their medications from their doctors, they are at greater risk as the doc likely isn’t fully aware of the other medications the patient is taking, a risk that would be substantially reduced if they went to their pharmacy, where the pharmacist likely knows if there’s going to be a problem due to an interaction between the new drug and the patient’s current medications. Walgreens et al knows this is one of their big value propositions – the added safety inherent in going to your pharmacist.
From a purely financial point of view, the chain drug stores are missing out on thousands of store visits as well, where the claimant picks up their meds and likely some toiletries and perhaps milk too.
There are over 1900 pharmacies operating in Illinois; if one was at the meeting they didn’t announce themselves.
On a broader front, the Federal work comp program implemented an almost-identical requirement about a month ago in a move undoubtedly applauded by everyone who pays income tax to the Feds. No longer will physicians dispensing drugs to Federal workers be able to inflate costs by using repackaged medications costing several times more than the same drug bought at a retail pharmacy.
There’s bad news as well, but we’ll save that for another time.


Jul
20

WCRI – under assault by physician dispensing company

After the release of its much-awaited update on physician dispensing in workers comp, WCRI found itself under verbal assault from physician dispensing company Automated Healthcare Solutions.
AHCS, perhaps the largest firm in the business (and partially owned by Boston-based ABRY Partners, who also owns Gould and Lamb and York Claims), said this about the study and WCRI in an email to WorkCompCentral’s Mike Whitely:
“It is not surprising that this unscholarly work is the vehicle being used to deliver a self-serving message the insurance industry wants the public to hear…Despite repeated requests, WCRI has refused to make available its underlying data for prior reports, which leads us to believe that this questionable work has not been properly peer-reviewed and has not been validated by an independent third party.”
Talk about cranky…
First, this statement is from the same AHCS that has repeatedly quoted WCRI in its written statements supporting physician dispensing of repackaged drugs. Including at the last Illinois fee schedule meeting, where AHCS employee Gary Kelman MD quoted extensively from WCRI’s previous work in an attempt to justify the higher costs and utilization patterns exhibited by physician dispensers. Their advocates have also used WCRI’s reports and statements in Hawai’i, where they succeeded in delaying controls over costs for physician-dispensed repackaged drugs
Second, WCRI has a well-deserved and long-held reputation for unbiased, high-quality and well-done research. If anything, critics (including me at times) have lamented the time it takes WCRI to produce reports. Aggregating data from different companies, ensuring data quality, reviewing findings, and QA’ing every analysis, calculation, result, and formula before you even get to writing up results takes a lot of time and talent, and that’s before you get to writing up the results and fact-checking each and every statement, figure, statistic, finding, and conclusion.
Third, WCRI is funded by a variety of sources, which AHCS could have checked easily if they wanted to – insurers, state regulators, labor organizations, employers, and others. Or perhaps they did and didn’t want to mention the broad funding and support base enjoyed by WCRI.
Let’s also not forget WCRI doesn’t take stands or suggest policy – they never have. That’s not their function, and it is one they take very seriously.
For AHCS to impugn WCRI is a classic case of shoot the messenger. Fact is physician dispensing drives up costs, enriches a very few physicians, dispensing companies, and private equity firms (ABRY in particular), and risks patient safety while increasing disability duration, hurting employers, and increasing taxpayers’ burden.


Jul
19

Physician dispensing in comp – growth is exploding

In Illinois, physician dispensed drugs accounted for almost two-thirds of all drug costs in 2010-11. Same in Florida.
Maryland – 47%; Pennsylvania – 27%; Tennessee 25%; Michigan – 22%.
The data are from WCRI’s just-released study on Physician Dispensing in Workers Comp, and reveal growth in physician dispensing that can only be described as “explosive”.
In Illinois, physicians’ share of all prescription costs increased from 22 to 63 percent of all prescription payments over 07/08 to 10/11.
You read that right; growth tripled over three years.
Even more revealing, the volume of scripts dispensed by docs grew from 26% to 43%.
You read that right too. In Illinois, costs went up more than twice as fast than the number of scripts, which means the physicians dispensing medications raised their prices dramatically. A specific example; the price of Vicodin purchased at a retail pharmacy dropped 2 percent, while physician dispensed Vicodin went up 66% over that three-year period.
Notably, prices did not change much in Florida, perhaps as physician dispensing firms and repackagers, responding to heavy political pressure, kept a lid on pricing rather than face added scrutiny.
The study reported on physician dispensing across 23 states, representing over two-thirds of all work comp benefits in the nation.
A couple other points deserving of attention. First, proponents of physician dispensing claim lots of benefits including increased compliance, lower cost, and more rapid return to work. Note that they make these claims without a single shred of evidence to support those claims. Contrast that with the overwhelming evidence – in this and other reports from WCRI, NCCI, CWCI and other sources – that clearly demonstrate the exploding costs of this practice, costs that are borne by employers and taxpayers.
Second, these proponents assert that limiting reimbursement to the price of the non-repackaged drug will mean docs won’t dispense (and thus won’t deliver the “benefits” noted above). Not true.
California instituted price controls limiting reimbursement to the price of the non-repackaged drug several years ago; over half of all scripts California are still dispensed by physicians, just as they were pre-reform.
There’s much more in WCRI’s study; lead author Dongchun Wang points out that prescribing patterns for dispensing docs are dramatically different than non-dispensing physicians, and docs have dispensed OTC medications and charged much higher prices than retail pharmacies.
NCCI reported physician dispensed drugs accounted for 28% of all drug costs back in 2008. Now, three years later, it could well be that two-fifths of drug costs are from physician dispensed repackaged drugs.


Jun
26

Progress on opioids – Texas leads the way

There’s precious little good news on the subject of opioid overuse in work comp; NCCI and WCRI report increased usage, pill mills abound, CWCI’s research shows longer disability durations, and payers lament their inability to do much of anything to fix the problem.
The last two weeks have brought news that is welcome indeed; early indications are that Texas’ adoption of a restricted formulary has led to significant reductions in the use of opioids early on in new claims, stakeholders are focusing on preparing to address legacy claims, and there may well already be some impact on legacy claims.
For those not deep into this issue, Texas is one of the few states (and almost all the others are monopolistic WC states) that has adopted tight guidelines re the prescribing and dispensing of opioids to workers comp claimants. These guidelines were imposed on all claims occurring on or after September 1 2011. While it is still early, preliminary research indicates a significant impact on prescribing and dispensing patterns. (the changes compare claims occurring from September to November 2011 to claims in the same timeframe in 2010)
– prescription drug costs for drugs “not recommended” (N) for 2011 claims were reduced by 75 percent when compared to 2010
– the number of claims receiving “N” drugs dropped by 54 percent
– total prescription drug costs for 2011 claims declined 26 percent – about $1.4 million
– “the frequency of opioid prescriptions dispensed to injured employees decreased by 10 percent and the costs associated with opioid prescriptions decreased by 17 percent”
Word is there has also been an impact on older, legacy claims. Anecdotally, PBMs are reporting they are seeing changes in prescriptions for some claims that were incurred long before 9/1/11.
The data from Washington state is another indicator that physicians can and do change prescribing patterns when forced to by regulation. Washington saw a significant decrease in the volume and potency of opioid prescriptions after passage of legislation addressing the issue.
What does this mean for you?
Prescribing patterns can be changed. All it requires is:
a) political will; and
b) tough regulations and/or legislation.


Jun
20

What’s a Prescription Monitoring Program and why you should care

Prescription Monitoring Programs are state-based electronic information systems that collect and deliver information about the drugs dispensed to patients, the prescribers thereof, and the pharmacies that do the dispensing.
Each state now has legislation enabling a PMP, with New Hampshire just added to the list. Not all are operational, and even among those that are there is wide variation among and between PMPs. Some are mandatory – that is, they require physicians and/or pharmacies to check them before prescribing or dispensing certain drugs. Others are optional – not surprisingly, usage in mandatory states is much higher than in those states where usage is optional.
What drugs are entered into the system also varies, with some states requiring much broader lists of drugs be tracked via their PMP – typically Schedule II – V Others only require tracking for the most potent Scheduled drugs.
PMPs can identify likely doctor-shopping and patients getting multiple fills for the same script, prevent duplicate fills, guard against dangerous drug-drug interactions, help law enforcement identify potentially fraudulent or criminal activity, and help physicians assess the risk in prescribing narcotics.
There have been some significant results. This from Brandeis’ University’s PMP Center of Excellence:
• Ohio – emergency department medical providers found that 41% of those given PMP data altered their prescribing for patients receiving multiple simultaneous narcotics prescriptions. Of these providers, 63% prescribed no narcotics or fewer narcotics than originally planned, while 39% prescribed more.
• California – 74% of physician responders to a survey indicated they had changed their prescribing practices to a patient as a result of using PMP Patient Activity Reports (PAR); 91% rated the “effectiveness of the PAR in maintaining the care and health of your patient” as good to excellent.
• Kentucky – A 2010 survey of users of Kentucky’s PMP, Kentucky All Schedule Prescription Electronic Reporting (KASPER), found that were an aid to clinical practice, with 70% of prescribers and dispensers judged PMP reports to be “very” or “somewhat” important in helping them decide what drug to prescribe a patient; 90% of prescribers and pharmacists “refused to prescribe or dispense a controlled substance based on the information contained in a KASPER report.”
• Louisiana – Five doctor shoppers who each obtained an average of 16.9 controlled substances prescriptions per month prior to rollout of the state’s PMP in September dropped to 0 prescriptions by December.
• As the Massachusetts PMP began sending unsolicited PMP reports regarding possible doctor shoppers to prescribers in 2010, prescribers were asked about the usefulness of the reports. Of the first 162 responders, only 14% said they were “aware of all or most of other prescribers,” and only 13% said “based on current knowledge, including the report, the patient appears to have legitimate medical reason for prescriptions from multiple prescribers.”
PMPs – properly set up and implemented – can be valuable tools in the battle against opioid abuse and diversion. Alas, the AMA and some other provider and “patient advocacy” groups find fault with PMPs, decrying the extra labor involved in ensuring patient safety and raising what are mostly ill-founded concerns with patient data.
There will be much more to come on PMPs; they need support, strengthening, and financial resources. Remember this.


Jun
14

PMSI’s Opioid Summit – part one

I was invited to attend PMSI’s Opioid Summit last month and speak briefly on legislative and regulatory actions focused on this issue. The Summit featured Colorado WC Medical Director Kathryn Mueller MD MPH; PMSI Medical Director Natalie Hartenbaum MD MPH; Len Kamen DO and addictionologist; and representatives from several insurance companies, all speaking on their efforts to identify and address potential overuse and misuse of opioids.
Here are a few of the highlights from the meeting. I’ll skip the discussion of the scope of the problem; it’s huge and growing, but it’s time to talk solutions.
First up, what is pain management – Dr Mueller cited the AHRQ Technical Brief on chronic non-cancer pain, noting in part “the focus is not eliminating pain but managing pain to restore physical and mental function and quality of life.”
That is a KEY issue – managing v eliminating pain. It is unrealistic to expect to eliminate pain, and attempting to do so is in large part how we got to this disastrous point.
Dr Mueller went on to review ACOEM’s recommendations for opioid use, which, when compared to what actually happens out there, are pretty remarkable.
Dr Hartenbaum discussed urine drug testing (UDT) in chronic pain and workers comp, citing the WOEMA comparison of opioid guidelines and noting there are various testing protocols;
– before starting a patient on opioids and annually up to four times a year – more if misuse is suspected.
– once per year for “low risk”, up to 4+ times per year for higher risk, high dosage (>120 MED (morphine equivalent dosage)) and/or patients exhibiting aberrant behavior. Hartenbaum cited the opioid risk tool as potentially useful in risk-scoring patients.
Her discussion of UDT was detailed, thorough, and enlightening. (disclosure, Millennium Labs is an HSA consulting client; they were not present at the meeting).
There was more, which I’ll relate tomorrow.


May
16

Missouri’s resident idiot

Earlier this month a physician legislator in Missouri blocked a bill setting up a prescription drug monitoring program, making MO one of two remaining states without a PDMP.
Oh, and the Show-Me state’s death rate from drug overdose (most of which is from prescription drug abuse) is higher than the national average…
For the uninitiated, PDMPs help ensure patient safety by identifying potentially harmful drug-drug interactions; enable prescribers and dispensers to see if a patient is filling the same scrip multiple times, and inform doctors and pharmacists when a patient is getting multiple scripts from multiple docs. And they comply with all patient confidentiality requirements.
Republican Sen. Rob Schaaf, henceforth known as Missouri’s resident idiot, spent eight hours filibustering the PDMP bill, ending with this brilliant justification for not protecting patients with a PDMP: “If they overdose and kill themselves, it just removes them from the gene pool.”
And if Schaff prescribes percoset and some other doc is prescribing oxycontin and a third is prescribing a sedative and the patient dies thru no fault of their own, and their kids lose a mom, and a Scout troop loses a den mother and a school loses a teacher, all because Schaaf is an idiot, whose fault is it?
What does this mean for you?
We get the government we deserve, and we deserve it good and hard (apologies to HK Mencken)


Apr
30

Pharmacy Benefit Managers – if they report, why doesn’t everyone?

Last week’s post on the recent release of Annual Reports by PBMs Progressive, PMSI, and Express Scripts, got me thinking (spurred by a friend’s query); if PBMs produce these reports as a matter of course, why don’t other specialty medical management companies?
The wealth of information contained in these reports provides readers with insights into cost drivers; pricing; changes in prescribing and treatment patterns; differences due to geography, claim duration, and diagnosis; new treatment options; and changes over time in all of these categories/metrics.
It strikes me that industry/speciality appropriate information would be pretty valuable and help differentiate as well.
PBMs have raised the annual report to an art form; PMSI’s is extremely detailed and clinically robust; Cypress Care’s upcoming report differentiates between older (> 3years) and new claims; Express focused on opportunities to reduce costs thru increased use of step therapy and generics; Progressive’s discussion of regulatory changes was comprehensive and thorough.
The short answer is “it takes a lot of resources.” True, but the payoff is likely commensurate with the investment. Others are concerned that somehow competitors will learn the ingredients of their “secret sauce” and use it against them. Possibly, but not if you’re smart and careful.
There’s precious little real differentiation in the managed care services industry. Clearly it’s working for PBMs; undoubtedly it will work in other sectors as well.
and a “thanks for the thinking” to Peter Rousmaniere.


Apr
26

Work comp drug trends reports – tis the season

Tis the season for drug trend reports. Recent releases from PMSI, Express Scripts (ESI), and Progressive Medical show an ever-increasing level of sophistication and growing insight into cost drivers in workers comp pharmacy. Moreover, the layout, graphics, use of charts and layout are far superior across the board.
I’d caution readers against using these reports to directly compare PBMs; mix of business/client base, average age of claim, jurisdictional market share, and other factors make direct comparison of statistical results inappropriate. For example, one PBM might have significant share of the state funds, other PBMs typically service large carriers; some may have a large book of older claims (with higher spend, more opioids, and lower generic fills) while other, newer PBMs will have fewer legacy claims.
Here are some of the highlights from each.
Industry founder PMSI has been producing reports longer than most; their latest release includes chief clinician Maria Sciame, PharmD’s video discussion of the report. It needs a bit of highlighting, as at 72 pages, it is by far the most voluminous of the studies. PMSI saw an average cost increase of 3.2% with a higher cost per script somewhat mitigated by lower utilization. (in fairness, PMSI’s book likely has a higher proportion of legacy, long-term claimants than other PBMs, again making direct comparisons inappropriate; their average claim is 4.9 years old)
Average blended prices (weighted brand and generic) were up 6.3%, driven almost entirely by an 8.3% jump in brand AWP. These increases were somewhat mitigated by PMSI’s high mail order penetration and the attendant lower customer pricing; due in part to their mix of business, 27.5% of their scripts were home delivered. Narcotic utilization per claimant also declined.
Of particular interest is the lengthy discussion of differences in drugs used by claimants as claims age. In general, costs, and the number of scripts, go up rapidly over the first six years, level off somewhat, then cost trends upwards again after ten years while the volume of scripts stays level.
ESI released their drug trends report a couple weeks back. The big news is spend – measured on a cost per user-per year basis – decreased by 1.8%, driven primarily by a drop in utilization. Notably, narcotic spend decreased 3.6%, influenced by a 6.2 percent decline in OxyContin(r) spend. Overall costs could have dropped further if claimants had taken full advantage of home delivery/mail order, maximized generic substitution, eliminated physician dispensing, and used in-network pharmacies.
Express focused their report on opportunities for payers to reduce costs by addressing unnecessary spend, or waste. Their estimates indicate payers could reduce costs by some $2.1 billion by eliminating “waste”. While most of this reduction would come from greater use of generics, ESI also noted a significant increase in the cost of compounds; over the last four years costs have more than doubled. Substituting commercially-available alternatives for compounds would save hundreds of dollars per script…
Progressive Medical reported a 1.3% drop in spend per claim for 2011 as well, with narcotics down 3.9%, this despite an average increase in AWP of almost six percent on a per-claim basis. PMI’s report provided detailed explanations of legislative/regulatory changes during 2011, as well as a lengthy, and informative forecast of issues including new drug approvals, FDA activities and societal issues affecting pharmacy management. Unlike other PBMs, PMI does not see third party biller activity as an issue. This is unsurprising, as their ownership by Stone River enables PMI to apply their negotiated discounts to all bills coming thru Stone River Pharmacy (the leading third party biller).
As with other PBMs, Progressive focused on compounded medications, with their data indicating a very small (1.2%) increase in the average cost of compounds, offset by a 3.9% decline in the percentage of claimants using compounds driven by PMI’s requirement that all retail-dispensed compounds go thru a prior-authorization process.
There should be a couple more reports out shortly; when they are we’ll get them out to you as well.


Apr
13

Express Scripts, Medco, and Walgreens – the deal

Now that Express Scripts’ takeover of Medco has gotten the okay by federal regulators, it’s a done deal. The new company will be the nation’s largest pharmacy benefit manager, with only CVS-Caremark
There’s pressure on Express to get this deal done as well, as sources indicate the giant PBM will make some clients “whole” on scripts purchased at Walgreens, albeit only for a limited time. That’s costing Express more money every day; while the “limited time” make-whole deal will expire (for many customers) at the end of June, customers will not take kindly to an end in Express’ subsidy of Walgreens’ scripts. Most assuredly Walgreens is well aware of the growing pressure on Express, and likely made the decision to wait it out, hoping that a) the Medco deal would be rejected by the Feds, and b) as the make-whole guarantees expired, Express would be forced to sweeten their offer to Walgreens.
Now that the deal has been approved, there’s a bit more pressure on all parties to resolve their differences, sign a new contract, and move on. While Walgreens is a major force in retail pharmacy with their 8200 stores making them the largest chain, ESI-Medco will handle a full 40 percent of all scripts in the US.
That’s just too much market share; Walgreens has to get a deal done. Script volume declined by 8% – 9% late last year, likely as a result of the loss of ESI contract. Now that ESi brings those scripts to the bargaining table, Walgreens will be hard pressed to come up with any business case wherein not contracting with ESI-Medco is viable.
But, many (including your correspondent) also thought the two parties would get a deal done earlier this year. There is always the chance that there’s just too much of a gap, and/or too much animosity.
And, Walgreens does have an alternative ‘strategic option’; they can acquire Rite-Aid, thereby upping the ante. That deal has been rumored for some time, and could be part of their overall negotiating tactics, as well as a long-term strategic move.
Of course, Medco has had and continues to have a contract with Walgreens, a contract that resulted in 125 million scripts for Walgreens. Now that Express and Medco are coming together, the Medco contracting folks may (pure speculation here) take the lead on resolving the issue. As they’ve not been involved in the previous (failed) negotiations, they may be able to resolve the impasse more quickly by not having to rebuild relationships and re-establish trust.
Remember – while the deal is between companies, the deal-makers are people, and people have to get the deal done. I’d bet they will, and give odds.
What does this mean for you?
Consolidation among the largest buyers of scripts may mean lower costs for their customers, but as the market consolidates further, it could may lead to monopolistic pricing.