APA Opposes Trump Administration Plan Targeting Psychiatric Drugs in Medicare
Mar 7, 2019 by Linda M. Richmond
The proposal would erode the protections now granted to most psychiatric medications in Medicare Advantage and Part D drug plans, subjecting them to prior authorization, step therapy, and exclusion from formulary lists.
APA strongly opposes a Trump administration prescription drug proposal aimed at patients in Medicare Advantage and Part D plans, saying that it would “impede patients’ access to lifesaving medications.”
The rule (CMS-4180-P), issued late last fall by the Centers for Medicare and Medicaid Services (CMS), would allow Medicare Advantage plans and Part D plans to reduce costs by adopting various new “utilization management tools.”
The proposal is a dramatic departure from current policy, which requires Part D plans to include on their formularies all drugs within six “protected classes,” including antidepressants, antipsychotics, and anticonvulsants.
Specifically, the proposed rule would allow Part D plans to implement prior authorization and step therapy, as well as determine the indications for which certain drugs could be prescribed. Part D plans could also exclude a protected class drug from their formularies in certain cases. As for Medicare Advantage plans, they would be permitted to apply step therapy for Part B drugs.
“The need for patients to have access to the medications is crucial, with suicide rates rising across the United States and emergency room boarding of patients with serious mental illness becoming a crisis for many hospitals,” APA CEO and Medical Director Saul Levin, M.D., M.P.A., wrote in formal comments that APA submitted to CMS in response to the proposed rule. “This proposal would exacerbate these issues without achieving the financial benefits expected.”
APA opposes the proposed rule because of the potential harm to patients and increased costs that come from patients being denied the medication that can best treat their symptoms due to the inherent complexity of psychotropic drugs and because no two psychotropic drugs are the same, Levin wrote.
“On average, plans currently cover just over two-thirds of drugs across all six of Medicare’s protected classes, and this incentivizes plans to further limit the availability of lifesaving medications,” he wrote.
Other concerns expressed by APA in its formal comments were the increased burden on physicians that the proposal would create as well as its interference with the doctor-patient relationship.
The American Psychiatric Institute for Research and Education of previously stable Medicaid conducted a study in 2011 of patients who were forced to switch to a Medicare drug plan and had to change medications because their refills were not approved. The study found that nearly two-thirds experienced adverse events, including emergency room visits, hospitalizations, homelessness, and incarceration.
“Having to clear the numerous administrative hurdles to deliver quality care takes valuable time away from patients,” Levin added. CMS considered implementing significant changes to Part D’s six protected classes in 2014 but ditched the plan due to overwhelming concern by physician, patient, and other advocacy groups.
Also critical of the CMS proposed rule were the National Kidney Foundation, the American Cancer Society Cancer Action Network, Biotechnology Innovation Organization, the Partnership for Part D Access, The AIDS Institute, and the Community Oncology Alliance. ■