3 Comments

Bill,

Your comments are spot on and this is a train wreck in the making. Pharmacy owners I speak with, unless clarification comes quickly and is crystal clear, will not stock some of these drugs. I suggest all mfgrs. in the program link in directly to all 62,000 pharmacies, issue the rebate at the point of sale, and pay PBMs $0.10 (or $0 for a 90 day supply) for their processing fee. So simple and straightforward.

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Thanks, Gary. I really appreciate your comments. Manufacturers want to forthrightly address these problems and try to make the IRA work. They are, however, stymied by CMS’s and HRSA’s failure to clearly permit drug makers to take the action necessary. It’s a problem of the government’s making. It’s entirely within their power to address. But they need to act and act quickly.

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Gary, you are correct. My family owns a couple of independent pharmacies. Implementing a rebate system directly at the point of sale would require significant changes to how claims are processed. Specifically:

Real-Time Eligibility Verification: A new or enhanced system would need to determine 340B eligibility in real-time, integrating with existing PBM and pharmacy management systems. This would involve significant investment in technology and coordination among all stakeholders.

Operational Complexity: Pharmacies would need to manage real-time rebates, adding administrative burden and potentially increasing operational costs.

Risk of Errors: Identifying 340B eligibility in real-time could lead to errors or disputes, given the complexity of patient eligibility criteria and dynamic inventory replenishment processes. ChooChoo!

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