NYS PHARMACY CONFERENCE MINUTES
OCTOBER 4, 2013
1. Welcome and Introductions
2. Agenda
- Approval of Minutes from June Meeting
- General items for Discussion- Question about whether to extend the timeframe for certain pharmacy conference meetings based on the agenda. All agreed to consider doing when we see agendas.
- Reports by State and Governmental Agencies
1. Bureau of Narcotic Enforcement, NYSDOH (T. O'Leary):
- Discussion about having routine meetings with BNE on pharmacy issues; Terry said after discussion and Q&A today we can plan another meeting later this month if needed.
- ISTOP update- pharmacists given access on 8/27, needed to fix one glitch and assume now working ok but let them know if not. 42K users since June when put enhancements in place. 73K searches being done on any given Monday. System working pretty well. Outreach to different medical societies and feedback has been generally positive. Main issue was signing up for HCS accounts. Online paper-less sign up process now in place. Takes BNE 30 minutes to 2 hours to input pharmacy data into PMP. Pharmacy community with few exceptions have been fantastic.
- One issue is that a pharmacy will tell BNE to tell vendor to do something and vendor asks BNE to tell pharmacy to do something. BNE gives instructions but shouldn't be the mediator.
- Errors are online and can be retrieved online to correct and re-submit. Working on a process to correct online. Update data submission/error correction manual just posted to BNE 10/4 on error correction (see the following links).
- Next step for BNE is unattended reporting. One pharmacy has signed up to do unattended reporting and working fine with UPHN lite. BNE just hired support staff to implement this with pharmacies. UPHN lite has been used in other areas like SPARCS data from hospitals etc.; Question about whether there were any security concerns with UPHN lite. Terry stated that they were confident that these were secure transmissions and it would be long time with big budget before BNE would be able to use FTP program.
- Also BNE is moving to e-prescribing and looking at audit reports. Regulations from DEA in effect but BNE has not sent out an approval to any pharmacy yet. BNE is finalizing registration forms to be used by pharmacies and should have it out soon. BNE not certifying applications, if certified federally BNE just needs pharmacies to let them know via their registration process which should be complete soon. DEA about to approve a pharmacy application. Date for prescribers to be required to e-prescribe is March 2015. No requirement for pharmacies to receive e-prescribing for controlled substances, only the prescribers. If out of state pharmacies want to fill NY written prescriptions they must be able to receive e-prescriptions and therefore register with NY BNE.
- DEA take back scheduled for October 26, 2013. Unclear whether it will go on if government shutdown still in effect.
- Two recent bills signed; One to schedule bath salts effective 90 days; Other bill is safe disposal of unused controlleds. It allows pharmacies to voluntarily take back from the general public. Currently prohibited federally but regulations proposed to change that. DEA stated they expect to publish in the Spring. NY law would take effect one year from federal reg change at which point BNE would have to put out their own regulations. Question on whether pharmacies can put drop boxes in long term care facilities which remains unclear- will have to see what federal regulations say.
- Terry cautioned against sharing HCS acct passwords or looking up people on the PMP not permitted to look up. Pharmacists may only look up an individual where there is a prescription presented to them and they are suspicious.
- Two dumbie names in the PMP to use in practicing use of the new system: Jack Spratt Jan 1, 1970/ Crystal Kringle Dec. 25, 1935 is DOB. Ability to see the screen shot has made a big difference with provider understanding and use.
- Current law does not give third party access to the PMP like health plans.
- Prescribers cannot consult PMP Friday for use Monday (can only look up to 24 hours prior to seeing them).
- BNE working to be interoperable with other states. However, no state contiguous to NY is ready.
- BNE has rolled out the critical error for the name field; data has really improved but still working to improve further. If practitioners identify errors/issues, BNE advises them to call pharmacy to change record and re-submit.
b. Medicaid, NYSDOH (J. Elkind/ M. Toohey):
- Plan B: Federal guidelines changed to require no prescription of women of child bearing age. Amending NY regulations to change Medicaid policy to conform to federal guidelines.
- AAC/COD Surveys: Goal to change reimbursement methodology based on cost. Moved target date to 2/1/14. One issue was not getting high enough responses to monthly surveys to do price updates. Did outreach and are seeing much better responses and get closer to finalizing methodology. COD- DOH working to determine whether there should be tiered-dispensing fees based on higher costs and they have built a statistical model to develop. Question on specialized packaging and whether COD would cover the costs. Geography may be a factor as well as specialized services. Question on whether there will be sufficient funding to appropriately pay/increase COD as expected and expecting lower ingredient cost reimbursement. DOH believes there will be. Activities to do prior to 2/1/14 AAC/COD planned effective date: stakeholder feedback on methodologies, SPA etc. Also need to determine methodology when they do not have an AAC for a drug. Other states that tier dispensing fee do not consider pharmacy types within tiers.
- Mail Order: Changes implemented per State Budget. Medicaid update went out outlining how each plan is implementing the changes. Question raised is how does pharmacy know if they are being offered a comparable price? If pharmacies have information/concerned that they are not getting that price, inform DOH and they will reach out to plans and investigate to ensure conformance. Do not share actual pricing information with DOH. How would pharmacy determine this? Question is if pharmacy feels they have a lack of information or reimbursement below cost. Deep discounts based on volume are why mail order pharmacies may accept much lower prices.
- Generic Price Escalations: Outdated FULs posing an issue. Ongoing problem, reimbursing too low. DOH created a workgroup and working on a policy piece and identify all drugs where FUL falls below price in order to try to address this issue. Request made to have DOH share list of drugs with plans so they can be made aware of drugs and make adjustments. DOH will share.
- Vaccine Update: Recent updates have been issued on new procedure codes for administration and dispensing. Updates on Medicaid pharmacy page of NYSDOH website, link below:
c. NYS Board Of Pharmacy (J. Croce/K. Leonard):
- Over 10K pharmacists certified to immunize; When Regents approved meningococcal they asked about any insurance barriers to cover. Board supports efforts to eliminate sunset, same county standing orders requirement and allowing pharmacists to give all adult immunizations. Also support students being permitted to give immunizations.
- Movement federally on compounding: US Senate approved Quality Security Act re: compounding (acknowledges traditional compounding but creates a new category for bulk compounding. Board question about who oversees? and track & trace; Question on how apply to long term care facilities- only affects if compounding and selling to outside party.
- Hoping for compromise of certified technicians in 2014. Issues with grandfathering and whether it affects ratio. A lot of comments on how to shape the bill with limited exemptions.
- Next BoP meeting October 29th at Albany College of Pharmacy in Albany. Working to schedule 10/28 meeting with students.
- Leadership Conference with NYSED Office of the Professions on October 30th.
- Safe Rx/Label and language regulations have been in place since early summer. If not in compliance, contact the Board to discuss plan. Question on complying with patient label requirements in certain settings where provider licensed to use medications in their scope but if sending prescriptions into facilities like assisted living where med techs administer. Then must comply. No SafeRx complaints by consumers to date.
- Board created Technology Committee: looking at technology and automation in practice. Technology Conference has been pushed back a few months and will provide an opportunity to look at the various technology options out there.
- Price Poster: finalized for 2014 and shared with Medicaid. Reminder that sign has to be posted that drug prices are available upon request. NYC also has additional requirements that must be met that prices must be immediately available.
- E-Licensing: NYS taking all licensing processes to go through a centralized licensing service with pharmacy first profession scheduled to go live. Implementation date end of November.
- CDTM: Board preparing report to the Regents on implementation, successes, issues etc. If have any information to share, send to Board ASAP. Report due in Jan. 2014.
- PAP program is still looking for pharmacists to serve as worksite monitors.
d. EPIC Update (D. Reed):
- Medicare Part D premium for NY benchmark has been reduced to $37..23; EPIC pays to the benchmark for Part D premium for those with incomes up to $22,000. Very few EPIC members will be impacted by this change. Benchmark plans have been released, CVS Caremark plans omitted because they are on probation so cannot solicit new members but 2013 members remain in those benchmark plans.
e. IPRO (A. Myrka):
- National Action Plan for adverse drug prevention comments due 10/4 (opioids, anticoagulants) to HHS.
- Need to advocate nationally for pharmacists as health care providers and that pharmacists can do POC testing via CLIA-waiver.
- Work with Care Transitions process to look at post discharge counseling and medication reconciliation. Looking at sharing instructions and information with pharmacies, facilitating with the hospitals.
- Looking at pharmacists that do bedside dispensing and counseling at discharge, all geared to safe transition home and preventing 30 day readmission rule.
- Also looking at nursing homes for aligning the Emergency Kits- alerts to nursing staff to prevent readmissions.
- A lot of questions re: pharmacies that deliver, co-mingling and unit dosing for patients in community setting.
- Working to bring stakeholders together on high blood pressure/hypertension management. Very interested in PCMHs with pharmacists involved in providing services.
f. Office for People With Development Disabilities now has a Pharmacy Director (Kimberly Rhodes).
g. Reports by Colleges of Pharmacy
- Albany College of Pharmacy and Health Sciences: Facebook page for pharmacy; Enrolled 192 P1 Albany, 47 VT campus; Students interested in collaborating on Pharmacy Day in March/April to host something for students at ACP; Working to make next BoP meeting at ACP; doing a Presidential nationwide search for College.
- D'Youville College of Pharmacy: 56 P4 students in advanced practice experiences, first graduating class mid-May 2014. Doing a lot of global pharmacy experiences for students.
- St. John’s University: New Dean at St. John's U in Queens effective August 1st. Welcomed new class at full capacity.
- Touro College: Incoming class 104 students over capacity; extensive electives program. Grant from Pfizer to increase number of pharmacists providing pneumococcal vaccine in Harlem involving community pharmacy with education and enrollment by residents. Seems that program is making a difference. NYSDOH is aware of this initiative.
- University at Buffalo: Over the summer, trained 80 pharmacists as immunizers. Expanding interprofessional programs; hired 5 more FT faculty; Expanded joint programs with most students in MBA/Pharmacist program. Jim O'Donnell new Dean. Opened drug take back kiosks at police stations, emptied 2X/week.
h. Reports by Associations
- ASCP: 3 regional meetings/year. Annual meeting in Seattle in November. Focus is key legislative issues like ISTOP. Trying to attract young people.
- Chain Pharmacy Assoc of NYS: Focused on the implementation of ISTOP, Safe Rx, and interested in AAC/COD results. For legislative issues-meningococcal vaccine takes effect 10/29, voluntary take back bill signed, DXM bill effective in 6 months (no sales to under 18, must ID- we successfully lobbied for local preemption, no log or sales placement requirements), Healthcare delivery models NYSDOH study due in one year, tech bill, MTM/CDTM. Annual meeting on December 11th in Albany with speakers (Larry Mokhiber, NYSBoP, Assemblyman John McDonald).
- PSSNY: Planning mid-winter conference in Saratoga Jan. 10-11, working closely with students, National Tweet-a-thon 10/3 on role of pharmacists to promote profession and patient education, legislative efforts: finalizing 2014 agenda- very interested in no mandatory mail order (AMMO) enhancements, Glick/LaValle sponsor a bill to require supervising pharmacist of out of state pharmacy sending into NY to have a NY license. DOH program bill for immunizations does not include interns and only adds Tdap. Expect to see legislation to require a patient to be contacted prior to having medication shipped to them (no automatic refills by mail). PSSNY's position on CDTM is that it should be permitted in any setting and for any licensed pharmacist. PBM regulation a priority. Board Member Patty Donato stated that NABP is meeting in October to discuss such regulation to guide states on best ways to regulate PBMs. Welcome input. Oct 22-23 Chicago. PSSNY also has an immunization cert program on Oct. 27th.
- AMCP: October 2011 OMIG gave up oversight of restricted recipient to health insurance plans who have to look at triggers for overutilization. Based on review it can result in prescriber/pharmacy restrictions. Medicare does not have the same ability to restrict so to really be effective in Part D, plans needs ability to restrict.
NY Pharmacy Lobby Day: looking at late March/April 8 so PSSNY will do outreach to Conference members on best dates.
3. Next meeting date: December 13th 10:30AM-2:30PM at PSSNY Office.