NASP’s Comments on the Office of Inspector General (OIG) Department of Health and Human Services (HHS) proposed regulation

The National Association of Specialty Pharmacy (NASP) is pleased to represent the entire spectrum of the specialty pharmacy industry from the nation’s leading independent specialty pharmacies and practicing pharmacists to small and mid-size pharmacy benefit managers (PBMs), pharmaceutical and biotechnology manufacturers of specialty drugs; group purchasing organizations; wholesalers and distributors; integrated delivery systems and health plans; and technology and data management companies.

NASP has submitted the following comments on the Office of Inspector General (OIG) Department of Health and Human Services (HHS) proposed regulation, “Fraud and Abuse; Removal of Safe Harbor Protection for Rebates Involving Prescription Pharmaceuticals and Creation of New Safe Harbor Protection for Certain Point-of-Sale Reductions in Price on Prescription Pharmaceuticals and Certain Pharmacy Benefit Manager Service Fees” [84 Fed. Reg. No. 25, February 6, 2019; OIG-0936-P; RIN 0936-AA08].

NASP engaged in an extensive process to obtain all stakeholder input through active collaboration with the NASP Executive Committee, Board of Directors, Government Affairs Committee members and ad hoc work groups to most effectively articulate our comments, concerns and recommendations.

NASP looks forward to continuing to work with the Department of Health and Human Services and the Office of Inspector General and on your behalf, to support policy reforms that will reduce costs to Medicare beneficiaries and the broader Medicare program for specialty drugs. Representing specialty pharmacy, we also seek to ensure such reforms do all of the following: reduce both upfront drug costs and overall health care costs through appropriate medication access, monitoring, and adherence; recognize the need to improve the transparency of fee and ensure needed protections; ensure a competitive balance for pharmacies and adequate network standards under the Medicare Part D program; and support access to prescribed specialty medications that are frequently the only medication option to manage complex patient health conditions.