BenMedica’s Response to CMS’ Proposal to Lower Drug Prices and Reduce Out-of-Pocket Expenses

Proposed Rule

The CMS’ proposed rule requires Part D sponsors to integrate a real-time benefit tool (RTBT) within an electronic medical record (EMRs).

This proposed rule overlooks the option of offering enhanced Formulary and Benefit (F&B) as a solution for prescriber access to more complete drug benefit information.

While we support providing more complete drug and benefit information to prescribers, we believe that RTBT does not offer optimal information during the prescription decision process and should not be required for every ePrescription written. Here are our key observations of RTBT’s place in e-prescribing:

Prescribers need access to better information when selecting a medication. Enhanced Formulary and Benefit data can provide actionable information so that prescribers can make the best choice the first time. The benefits of Enhanced F&B include:

  • Uses the same source as RTBT

  • Can be configured to offer prescribers copay information and plan coverage while they are selecting a drug to prescribe

  • EMRs are already equipped to display F&B data today if the data is available

  • Offers clarity on preferred drugs and therapeutic alternatives

RTBT has challenges that need to be addressed before it is ready for mainstream use and Formulary & Benefit data is actionable now. A few of the challenges include:

  • No approved industry standard for RTBT

  • Many EMRs have not implemented RTBT

  • Provides information too late within EMR workflow

  • Many prescriptions will need to be rewritten after real-time data indicates a change is needed

  • If used for every prescription, increases physician time away from the patient during patient visits

A Comparison Between F&B and RTBT Capabilities

Here is an overview of the capabilities of Enhanced F&B and RTBT.

 
Comparison of F&B and RT Capabilities.jpg
 

As this chart indicates, Enhanced F&B is a solution that leverages existing technology infrastructure to provide prescribers with actionable information today.

Our Suggestions to CMS

We believe CMS should encourage more comprehensive and enhanced F&B files and leverage RTBT as a supplement to F&B for affirmation and complex,higher cost medications. With these two solutions, prescribers will be better equipped to select the best drugs for their patients.

Read our full response here