[Pharmwaste] CMS Proposes "Trial Sizes" Of Prescriptions To Curb Waste Of Unused Drugs In Part D

Gressitt, Stevan Stevan.Gressitt at maine.gov
Wed Feb 24 13:12:42 EST 2010

Subject: CMS Proposes "Trial Sizes" Of Prescriptions To Curb Waste Of
Unused Drugs In Part D 

February 24, 2010 

CMS Proposes "Trial Sizes" Of Prescriptions To Curb Waste Of Unused
Drugs In Part D 

CMS, in an effort to contain health care costs and the waste associated
with unused drugs, is asking Medicare Part D prescription drug plan
sponsors to allow beneficiaries to get a seven- to 14-day supply of a
medication that is new to the beneficiary.

In a draft version of the 2011 Part D plan call letter released Feb. 19,
CMS asserts that a trial-size fill of a new medication would motivate
"the beneficiary to request partial fills in order to gauge tolerance of
the new drug. By allowing plan members to obtain a partial fill for new
medications, the member may try the medication and return to the
pharmacy for the full amount when the patient has demonstrated a
tolerance for the new medication." Current physician prescribing
patterns and pharmacy benefit management practices typically result in
most prescription medications being dispensed for 30- or 90-day periods,
the agency says.

CMS also says that when the full dispensed amount of drug is not
utilized by the patient due to death, adverse reactions, medication
substitution or other reasons, "the remaining unused medication becomes
waste." The agency adds that it also becomes an environmental hazard
when it is disposed and could be a safety hazard in the home or diverted
for illegal usage.

The availability of trial size prescriptions "may serve as a substitute
for physicians' practice of giving patients samples of medications that
may not be compatible with the patient's Part D plan formulary," CMS

Finally, the offering of trial sizes "promotes savings to the
beneficiary, Part D sponsor and Medicare program," though the agency did
not quantify how much could be saved.

CMS notes that a review of 2007 prescription drug event data "suggests
that up to as many as 30 percent of first fills for chronic medications
are not refilled. If the disincentive of paying the full cost sharing
amount was eliminated, and copays were prorated for the amount actually
dispensed, beneficiaries might appreciate the opportunity to request an
initial trial fill for new medications."

The annual call letter outlines rules for Part D plan sponsors to use in
designing their plans for the upcoming year.

The draft call letter also brings attention to the transference of
coverage of drugs used to treat end-stage renal disease from Part D to
Part B. CMS currently is reviewing rules for a prospective payment
system that would bundle all ESRD services and drugs, which would be
paid under Part B.

CMS also is seeking comment on a proposal to include low-income subsidy
recipients who have chosen their plans among those CMS can reassign to
new plans based on plan bids. Previously, the agency only has reassigned
those who were auto-enrolled in a plan.

"For the fall of 2010, we are considering expanding reassignment to
these 'choosers' based on their 2011 premium liability, for example, if
their 2011 premiums will be $10 or greater. We are concerned that these
beneficiaries - despite targeted outreach - may not fully understand
they have less expensive alternatives."

The change could lead to the reassignment of 580,538 beneficiaries,
based on the number of 2010 LIS choosers in plans with premiums of $10
or more.

CMS says in the draft letter that it is planning on maintaining the $600
threshold for drugs in the specialty tier.



Stevan Gressitt, M.D., Medical Director

Office of Adult Mental Health Services

Department of Health and Human Services

Marquardt Building, 2nd Floor

11 State House Station

32 Blossom Lane

Augusta, ME  04333-0011

Ph: (207)287-4273

Fax: (207)287-1022

Cell Phone: (207) 441-0291

E-Mail : stevan.gressitt at maine.gov



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