Paul Fogg, Marquis Companies

Ensuring the provision of quality post-acute care in skilled nursing and assisted living facilities requires the need to direct and perform an increasingly complex array of medication management regimes and clinical functions. In today’s quality-intensive care environment, this means the expertise of long-term care pharmacies, and the consultant pharmacists out on the front lines of care, have never been more important.

Moreover, this is a primary reason we formed the Senior Care Pharmacy Coalition in late 2014. The ever-changing multiplicity of federal laws, regulatory mandates and payment methodologies absolutely requires full-time federal advocacy attention solely devoted to LTC pharmacies and the growing number of patients under our care.

Our long-term public policy successes in Washington – and our members’ long term success in the changing market environment – are predicated not just upon SCPC’s ongoing ability to be a credible, trusted voice on policy, but ensuring we have the capacity, resources, scale and bipartisan policy solutions to actually affect it

When I succeeded SCPC’s founding Board Chairman Michael G. Bronfein last October, my top organizational priority was to establish an LTC-specific data warehouse to build and expand over time — enabling us to sustain the leadership role we have earned in driving policy and advocacy work through the lens of credible third-party research.

For too long, the LTC pharmacy sector has had to rely solely on anecdote to help persuade policy makers, aside from the sector-specific research projects SCPC has undertaken since its inception in late 2014. There simply are no publicly available sources of data concerning Medicare Part D, LTC pharmacy economics or LTC pharmacy quality. Without data and analysis, this sector simply cannot compete in the top echelons of Washington policymaking.

We are proud to now say that SCPC has reached another organizational milestone and has engineered the initial infrastructure necessary to appropriately collect, tabulate and analyze data from our growing number of member pharmacies. Among other key projects, SCPC will continue to develop its research effort aimed at quantifying PBM reimbursement inequities driven by the Maximum Allowable Cost (MAC) pricing shell game used to establish payment rates for a majority of generic drugs LTC pharmacies dispense to elderly Medicare beneficiaries.

An earlier SCPC study by Avalere Health shows that MAC prices paid for the same generic drugs on the same day by different payers can vary considerably — which we contend raises questions about the relationship between price variation and actual market conditions. For the sake of credibility and accuracy, we specifically noted when we released the study that while we could make pertinent observations about the findings, we could not make more determinative conclusions due to the limited volume of data initially analyzed.

Now, with our own internal LTC pharmacy data capacity, we will be able to capture and analyze a vast amount of transaction data with which to make more determinative conclusions for lawmakers and regulators who want, need and will act upon credible, non-biased, fact-based research.

On a broader level, our mission of educating lawmakers about opaque PBM pricing practices — and their highly —negative impact on seniors and LTC pharmacies’ ongoing ability to provide key clinical benefits and medication management services — has been helped by the avalanche of negative PBM publicity regarding their role in driving higher drug prices. But we cannot depend upon negative headlines and third parties, we must depend upon ourselves, and now we can.

The simple truth of the matter is that the more real data and facts about improper PBM practices are placed in the public domain, the more we will see lawmakers employ them to achieve desirable public policy achievements in the areas of pricing transparency, real free markets and, ultimately, lower prices for the medications senior lives depend upon. SCPC looks forward to detailing and releasing a regular flow of the LTC pharmacy-specific data we have needed for so long. 

Phil Fogg Jr., is president and CEO of the Marquis Companies based in Milwaukie, OR.  He serves as Chairman of Board for the Senior Care Pharmacy Coalition and also serves on the Board of the American Health Care Association.