The voice for pharmacy compounding | October 16, 2020
THIS EDITION SPONSORED BY PCCA
Pharmacy compounding's biggest annual event -- PCCA International Seminar -- is VIRTUAL this year from November 5-7, 2020. Get ready for 3 half days of compounding education and virtual networking with your fellow compounders.
This week's good news about our success in turning back that TRICARE recoupment -- read about it below -- makes me want to dance a jig, but I'm scared I'd throw my back out.
So I'll just note that for the 400 compounding pharmacies that were facing that outrageous accusation of fraud, we came through. Thanks to APC and NCPA -- we're deeply grateful to our partner NCPA -- a great wrong was turned back.
It pays to be a part of this association, doesn't it?
I know I'm preaching to the choir, but here's why I'm preaching: On this past Wednesday's APC Tricare Recoupment Briefing Call where we announced the good news, MORE THAN 60 OF THE 120 REGISTRANTS WERE NOT MEMBERS OF APC.
Some of them used to be members but didn't renew. Some of them may have thought they were members because they work in a pharmacy where someone else is a member. But no. Half the participants reaped the benefit of APC's work, but don't belong.
Rather than be annoyed by that, let's see it as an opportunity. There are pharmacists and technicians on your team who aren't members. Urge them to join. A nudge from you will go a long way. And if you point them to A4PC.org/join, they can use the code APC2020 to get $25 off the dues amount.
Now enjoy this week's good news -- and feel free to dance a jig. Just mind your back.
Don't miss the important APC briefing on the threat to cBHT
On October 22 from 3:00 - 4:00pm EDT, APC will host a free briefing for the compounding community on the potential FDA threat to compounded hormone therapy: What we know, what we're doing, what you can do to help.
In the wake of that flawed NASEM study, FDA has said it will consider restricting compounded hormone therapy. It's likely that cBHT patients are a good share of your business, and that the therapies you prepare have helped those patients immensely.
Although FDA has not yet proposed specific restrictions, NOW is the time to begin to educate your member of Congress about cBHT -- and to ask them to sign-on to joint congressional letter to FDA raising concerns about the NASEM cBHT study that FDA funded.
Ask your U.S. House member to sign the joint letter to FDA sponsored by Reps. Pocan, Herrera-Beutler, Cuellar, and Roe. Use the first link yourself, and share the other with your patients.
The Tricare recoupment fiasco faced by hundreds of pharmacies across the country appears to be nearing the end, with a victory for pharmacists in sight.
In response to concerns raised by APC and its partners -- and vigorous lobbying -- Tricare has instructed Express Scripts to stop the recoupments it started in June. Pharmacies that have already suffered clawbacks will be allowed to appeal, and the standard for documentation of those appeals will now be reasonable.
APC teamed with NCPA and PAAS National to challenge the recoupment, and, over a series of conference calls with Tricare and ESI, were able to demonstrate how the recoupments themselves were often invalid, and the requirements for appeal were egregious (and, frankly, bordered on the absurd).
Attorneys Hunter Jamerson of Macaulay & Jamerson and Jeff Baird and Brad Howard of Brown & Fortunato were instrumental in assisting the recoupment challenge.
Now some pharmacies will even be receiving an apology from ESI.
There are caveats (see below), but perhaps the most important news: ESI and Tricare are no longer considering this issue to be one of fraud, waste, and abuse. Instead, for those already recouped, it's more a typical audit.
The hundreds of compounding pharmacies that received clawback letters in June will be receiving one of three new letters from ESI depending on where they were in the recoupment process.
Pharmacies that have not had any funds recouped: It's over. Probably. "No further action is needed by your pharmacy at this time as this letter supersedes all previous communication on this matter," states the letter, although it also says that "DHA and ESI intend to re-evaluate the claims at a later date."
Pharmacies that have been partially recouped: The recoupment is stopping ("All other claims from the April/June communication have been released from recoupment or offset") and you will have 90 days from when you received that letter -- expected to mail the week of October 18 -- to appeal.
Most important: Tricare is no longer demanding the kinds of records pharmacies are unlikely to have, e.g., proof of a prescriber-patient relationship. It now only expects the kinds of documentation a pharmacy collects in the normal course of business: "including copies of the original prescription and any other documentation your pharmacy may have through the normal course of business pertaining to this matter. Supporting medical records or attestations from the prescriber are not required elements of the criteria for a successful appeal." (Emphasis ours.)
But, as attorney Hunter Jamerson put it, any relevant documentation you can supply is good. "If it's within your reach -- and in particular your reasonable reach -- it's not going to hurt and it will probably help."
Pharmacies that have been fully recouped: As with partial recoupments, you will have 90 days from receipt of this new letter to appeal, and that appeal only requires "documentation your pharmacy may have through the normal course of business pertaining to this matter."
"Never underestimate the ability of associations like APC and NCPA to get things done for their members," said APC CEO Scott Brunner.
Questions and answers
Participants in APC's October 14 Town Hall meeting had some relevant questions -- when will money be returned, what about earlier appeals, is it safe to continue to bill Tricare, and more.
Well-known women's health expert Dr. Pam Smith is offering to educate your patients on the importance of hormonal balance
Here's her offer for APC members:
She will conduct a Zoom-based webinar to educate consumers (i.e., your patients) during the day or evening. These will be interactive, with time for plenty of questions.
Your cost: The purchase of one case of Smith's book, What You Must Know About Women's Hormones, on November 10, for distribution to patients. (Your purchase will also help increase public awareness of hormone replacement for women.)
If you are interested, send and email to faafm63@yahoo.com, and Smith's assistant Kathy will help schedule the event and provide advertising materials.
You need a sales strategy. You need President Shawn's webinar.
ARL and Letco are offering a one-hour webinar, free to APC members
On October 28, APC President Shawn Hodges will present "Much More Than Selling Compounds!" from 1:00 to 2:00pm EDT. All APC members are invited, free - and it's worth 1 CE credit hour.
Get ideas on how to develop an effective sales strategy and call plan -- one that gets the most out of sales reps and increases customer loyalty. And that means your pharmacy can have a bigger presence in the healthcare community.
Hear experiences (both good and bad) on attempts to improve customer loyalty, and learn some specific sales tactics and tools that your sales reps can use right away.
This week APC submitted its comment letter to FDA on GFI #256, regarding animal compounding. (The comment deadline was yesterday, October 15.) Among other concerns, the letter asserts that FDA does not have clear statutory authority to regulate animal compounding via a guidance for industry document.
Join APC on October 27 from 2:00 to 3:00 pm EDT for our hot new CE webinar. You'll learn how improving sales can also improve patient care: You can drive compliance and offer 'companion items' that may improve their therapy or quality of life.
Learn not only how to incorporate your technicians, but how to work with outside sales representatives, too. You'll be taking notes like crazy with these practical and easy-to-implement steps.
We've hit more than 1,500 so far, but we'd like even more. Share your testimonials and tell your patients: We need to show Congress and FDA how important compounded hormone therapy is to millions of patients.
