Alliance of Independent Pharmacists of Texas

Hurricane Harvey Emergency Resources

Healthcare Ready's Rx Open is an interactive map that helps patients and providers find nearby open pharmacies in areas impacted by disaster. The map will be updated daily throughout the federally declared disaster. If your status is not accurate or you want to enroll your pharmacy, please send an email with your name, the name of the pharmacy, and the NCPDP or NPI number for the pharmacy to Healthcare Ready at ContactUs@HealthcareReady.org or call 1-866-247-2694.

Emergency preparedness "refill too soon" edit override: Reminder: NCPDP members have approved the most effective method for overriding "refill too soon" type reject during a disaster: using the Submission Clarification Code 13 - Payer-Recognized Emergency/Disaster Assistance Request. The pharmacist is indicating that an override is needed based on an emergency/disaster situation recognized by the payer. Access more information from NCPDP on Emergency Preparedness.

Texas health officials have issued guidance for Texas pharmacies that need to dispense emergency refills.  Click here for information from the Texas Board of Pharmacy.
 
The Department of Health and Human Services has declared a public health emergency and the CMS 1135 waiver program is now available. Certain requirements for Medicare, Medicaid and CHIP are modified to ensure needs are met and providers and suppliers acting in good faith are reimbursed.  Find out more details on the CMS website. 
 
Healthcare Ready is standing by to learn of health care needs and gaps. If there are any needs regarding infrastructure, transportation or supplies that arise, please contact them directly alerts@healthcareready.org or 1-866-247-2694.
 
The Emergency Prescription Assistance Program is on standby should Texas officials request activation.  When activated, EPAP functions as a third-party payer to process claims for certain kinds of prescription drugs, specific medical supplies, vaccines and some forms of durable medical equipment (DME) for eligible individuals in a federally identified disaster area.  Information for pharmacies, including the database of enrolled pharmacies, is available here.

Texas State Board of Pharmacy Emergency Procedures

Texas Vendor Drug and Procedures

 

End of Session Report

The 85th Regular Session adjorned Sine Die Memorial Day, May 29. The fate of the Alliance priority legislative issues that passed are now in the hands of the Governor. We have worked on several issues that directly impact your profession and small business. The Alliance will provide a final report in the weeks to come and again after the Governor's veto period ends in June, until then, the following important pharmacy issues have been sent to the Governor's office as follows: {Download print version}

PBM Reform

HB 3218, regulates the mysterious middlemen of prescription drug benefits (PBMs), regulating PBMs that contract with HMOs by requiring them to disclose their business practices, including Department of Insurance (TDI) jurisdiction and oversight into complaints, payment to pharmacies, prior authorization processes, credentialing, contracts, and other administrative duties.

HB 3218, an Alliance priority, requires PBMs that contract with pharmacies to comply with all laws and rules that apply to HMOs and requires PBMs to register as "delegated entities." Signed by the Governor Thursday, June 1 and is effective September 1, 2017.

Mandatory HHSC Audits of PBMs in the Medicaid Program

SB 894 requires statewide audits of Medicaid PBMs to comply with all laws, rules, and contract requirements of MCOs, including oversight of payment and benefits administration. This legislation requires MCO PBMs to be audited by a third party every two years.

Management of the Medicaid Drug Formulary

HB 1917 continues the administration of a statewide formulary, preferred drug list, and adherence to prior authorization procedures and requirements of the Health and Human Services Commission, Vendor Drug Program. 
The measure allows pharmacy to continue to advocate for a single statewide PBM or pharmacy benefits administrator for the Medicaid program with adequate reimbursement guidelines.

Read more...
 

Congress Preserves Access to Office-Use Compounding to Patients


International Academy of Compounding Pharmacists (IACP) reported yesterday the President has signed the Consolidated Appropriations of 2017 (H.R. 244). The bill supported by numerous national and state pharmacy organizations including the Alliance, provides funding for the federal government through September 30, 2017, and includes language that addresses the Memorandum of Understanding (MOU) for office-use and pharmacy inspections.

This bipartisan legislation includes critical language which clarifies congressional intent on several compounding regulations implementing the Drug Quality and Security Act (DQSA) of 2013.

The language calls on FDA to do the following:

  • Draft a new MOU that does not include "dispensing" of compounded prescriptions across state lines. Congress expressed concern that the FDA draft MOU includes both "dispensing" and "distribution" of compounded medications. Congress made clear in the language that FDA does not possess this authority and specifically stated, "Congress only allowed the FDA to regulate distribution" under the MOU and "Congress did not intend to include dispensing of compounded drugs over state lines within the scope of the MOU."
  • Release new guidance to allow 503A pharmacists to compound for "office-use" for prescribers, hospitals, and other health systems. Congress expressed concern that patient access is decreasing to compounded medications, due to FDA's implementation actions of prohibiting all office-use compounding even where "this practice is authorized in the vast majority of states and was intended to be allowable under DQSA." 
  • Cease inspecting state-licensed 503A pharmacies under current Good Manufacturing Practices (cGMPs). Congress instructed FDA to inspect 503A pharmacies under USP standards or other applicably pharmacy inspection standards adopted by state law or regulation. Congress also stated it "reminds the FDA that compounding pharmacies are not drug manufacturers, but rather, are state licensed and regulated health care providers that are inspected by state boards of pharmacy pursuant to state laws and regulations." Congress further stated, "compounding pharmacies are more appropriately inspected using USP standards or other pharmacy inspection standards adopted by state law or regulation in the state in which a pharmacy is licensed."

We are pleased Congress has preserved patient access to compounded medications from their local independent community pharmacists.

 

CMS Recommends State Medicaid Programs Expand Scope of Pharmacists

Aligned with Alliance initiatives, the Centers for Medicare & Medicaid Services (CMS) released a guidance this week encouraging state Medicaid programs to consider expanding the ability of pharmacists to prescribe, modify, or monitor drug therapy to promote patient access to medically necessary and time-sensitive drugs. CMS notes expanding pharmacists' scope of practice allows states to facilitate timely access to medications and can help address priority public health issues. Read more

 

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