OREGON HEALTH AUTHORITY

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1 HEALTH WEALTH CAREER OREGON HEALTH AUTHORITY PROFESSIONAL DISPENSING FEE SURVEY February 2, 2017 Presenters Shawna Kittridge, Mercer Jim Cook, Mercer Ralph Magrish, Mercer Scott Banken, Mercer Deborah ( Dee ) Weston, OHA

2 AGENDA WHAT WE LL COVER TODAY Covered Outpatient Drugs Final Rule Professional Dispensing Fee Survey Suggestions and Q&A 2016 MERCER LLC 2

3 COVERED OUTPATIENT DRUGS FINAL RULE 2016 MERCER LLC 3

4 OREGON S AAC PROGRAM COMPLIANCE WITH THE COVERED OUTPATIENT DRUGS FINAL RULE Oregon implemented its AAC program in 2011 Oregon already meets the ingredient and professional dispensing fee requirements of the final rule Reimburses pharmacies based on a state specific AAC program for ingredient costs Last conducted a cost of dispensing study in 2010 Commissioned Mercer to conduct a new professional dispensing fee survey OHA wants to ensure professional dispensing fees are reflective of the actual cost of dispensing to Oregon Health Plan (OHP) open-card (fee-for-service) enrollees Required as part of State Plan Amendment (SPA) submission process to CMS Effective date of final rule is April 1, 2016 States have until June 2017 to submit State Plan Amendment (SPA) 2016 MERCER LLC 4

5 PROFESSIONAL DISPENSING FEES FINAL RULE REQUIREMENTS Reflect professional services and costs associated with filling a Medicaid prescription Not intended to offset loss of payment for ingredient cost Appropriate to ensure adequate access Various data-driven methodologies will be considered by CMS State flexibility to adjust reimbursement for certain provider types and services 2016 MERCER LLC 5

6 WHY WHO HOW OHA is conducting a Professional Dispensing Fee survey All Oregon Health Plan FFS opencard participating outpatient pharmacies Mercer will Administer survey Conduct statistical analysis Produce report for OHA 2016 MERCER LLC 6

7 SURVEY WEBSITE Mercer s website for OHA survey activities Details and instructions for the survey Website details Link for direct access to Mercer s dispensing fee survey tool Downloadable templates for survey submission Questions and survey support RXSurvey@mercer.com 2016 MERCER LLC 7

8 SURVEY PROCESS Stakeholder meeting Statistical analysis Stakeholder feedback Professional Dispensing Fee Survey Survey data response validation Survey tool development Survey distribution and follow-up 2016 MERCER LLC 8

9 CHECKLIST WHAT YOU LL NEED Preparing for the survey resources needed Financial statements or tax returns From last completed fiscal year (12 months) Demographic information Pharmacy contact information and pharmacy type Prescription counts Floor plans Showing square footage or measurements of the pharmacy (prescription) area and the nonpharmacy (retail) area Certification Signature required (electronic or printed and scanned) For same time period as financial statements or tax returns 2016 MERCER LLC 9

10 TYPES OF COSTS Types of Costs Direct pharmacy costs Indirect pharmacy costs Facility costs Other administrative costs Direct non-pharmacy costs Unallowable costs based on Code of Federal Regulations (2CFR ) Lobbying Advertising Bad debt Income tax 2016 MERCER LLC 10

11 TOTAL CALCULATION Direct pharmacy expenses Allocated overhead (indirect) SUM Number of scripts Payroll Nonpersonnel costs Facility costs as a percentage of square footage Other expenses allocated as a percentage of sales In total Medicaid only 2016 MERCER LLC 11

12 ENTERING DATA Profile Information For identification and explanation of certain costs For comparison groups and to identify statistically significant causes in varying rates Does the provider dispense 340B Drug Pricing Program (340B) drugs? Type of ownership? Was there a change in pharmacy ownership during the reporting period? Was the pharmacy open the entire year? Is one or more of the pharmacists who fill prescriptions at this location also an owner of the store or chain? How many hours per week is the pharmacy department open? (maximum of 168 hours) 2016 MERCER LLC 12

13 ENTERING DATA Prescription Statistics How many were filled by this pharmacy for the following categories during the reporting period? How many were compounded? How many were delivered? Medicaid covered prescriptions Medicare Parts B, C, and D- covered prescriptions (If available) How many Medicaid prescriptions were compounded? How many Medicaid prescriptions were delivered to members? All other prescriptions (not Medicaid or Medicare) 2016 MERCER LLC 13

14 ENTERING DATA 340B 340B Type of 340B provider Does provider use a 340B administrator? Covered entity or contract Enter the total number of 340B prescriptions filled during the reporting period Does provider purchase drugs through the prime vendor program? Enter the total number of 340B prescriptions billed to Medicaid 2016 MERCER LLC 14

15 ENTERING DATA Sales and Cost of Goods Sold Sales (Pharmacy) Cost of Goods Sold (COGS) Prescription sales other than Over-the-Counter (OTC) dispensed by a pharmacist or 340B sales OTC sales dispensed by pharmacy department Sales of drugs purchased through the 340B program Sales (Non-Pharmacy) OTC sales dispensed by staff not in pharmacy department Portion of federal grants attributable to pharmacy, if any Other sales such as retail sales and HCPCS billed services Pharmaceuticals Note: This will not be included in the dispensing fee calculation Non-pharmacy COGS 2016 MERCER LLC 15

16 ENTERING DATA Payroll Expenses Owner pharmacist costs Non- Pharmacy payroll Pharmacy payroll (staff pharmacist costs; other pharmacy staff costs) Admin/ Overhead payroll 2016 MERCER LLC 16

17 ENTERING DATA Non-Payroll Expenses and Unallowed Costs Direct pharmacy, non-payroll expense CMS-defined unallowed costs (advertising, charity, income tax) Overhead facility costs (allocated by square footage) Overhead non-facility costs (allocated by percentage of sales) 2016 MERCER LLC 17

18 SUBMITTING THE SURVEY Certify the results Complete the survey Online OR Online OR Enter your name and title Printing, signing and scanning or taking a picture of the signed certification Click Submit Send completed spreadsheet to RXSurvey@mercer.com All completed surveys are subject to data validation May be asked to submit financials or tax returns, floor plans, etc MERCER LLC 18

19 TOTAL CALCULATION Direct pharmacy expenses Allocated overhead (indirect) SUM Number of scripts Payroll Facility costs as a percentage of square footage In total Non-payroll costs Other expenses allocated as a percentage of sales Medicaid only 2016 MERCER LLC 19

20 WHEN HOW The survey collection period is February 17 March 10, 2017 Mercer s Oregon survey website at Mercer s survey box: RXSURVEY@mercer.com 2016 MERCER LLC 20

21 QUESTIONS 2016 MERCER LLC 21

22 2016 MERCER LLC 22

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