Oct 16 -- The Centers for Medicare & Medicaid Services (CMS) invites comments to OMB by November 20, 2023 regarding the Survey of Retail Prices (CMS-10241). [Comments due 30 days after submission to OMB on October 20.]
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 includes 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.
CMS has been performing a “Survey of Retail Prices” since 2011. This contract leverages a voluntary, monthly survey to collect drug ingredient costs from retail community pharmacies. Specifically, respondents’ data are used to develop average acquisition cost (AAC) based pricing for covered outpatient drugs purchased by retail community pharmacies, which is updated on a weekly basis and posted on Medicaid.gov.
Since the inception of the monthly survey of retail community pharmacies, CMS has been using verified survey data to generate a publicly-available pricing database entitled the National Average Drug Acquisition Cost (NADAC) file. CMS has consistently received a sufficient number of monthly responses to develop statistically significant measurements of average cost for the purposes of publishing the NADAC benchmark according to its initial methodology. NADAC 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 as a component of their Medicaid pharmacy reimbursement methodologies.
The methodology for the NADAC file, which outlines data quality requirements and provides a full description of the file, is publicly available at
https://www.medicaid.gov/medicaid-chip-program-information/by-topics/prescription-drugs/ful-nadac-downloads/nadacmethodology.pdf.
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 NADAC files for states to consider when developing an 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. By facilitating a national survey of pharmacy acquisition costs, and making the resulting pricing benchmark available for states to use, CMS is significantly reducing the burden on states and retail community pharmacies that would occur if states were each obligated to produce their own pricing benchmarks.
Currently, up to 6,000 retail community pharmacies are randomly selected each month and have the option of voluntarily completing the survey. The initial sample size for the NADAC survey was determined during a time period when the NADAC was in development, but prior to the implementation of CMS-2345-FC and the adoption of the NADAC as the primary reimbursement benchmark for most state Medicaid programs. There are currently in excess of $20 billion dollars of Medicaid pharmacy claims paid each year based on the NADAC file. The increased reliance on the NADAC file for claims payment significantly impacts the need for a robust and reliable source of survey data.
This 2023 iteration propose to remove the “Cover Sheet” and the “Dear Pharmacy Letter” since the upcoming mailings will consist only of a revised “Survey Tool.” We are also adding a Spanish version of the survey tool which is intended for retail community pharmacies in Puerto Rico.
CMS submission to OMB:
https://www.reginfo.gov/public/do/PRAViewICR?ref_nbr=202310-0938-004 Click on IC List for questionnaire, View Supporting Statement for technical documentation. Submit comments through this site.
FRN:
https://www.federalregister.gov/d/2023-22791 #1
For AEA members wishing to submit comments, "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