Advocacy Letters and Policy Documents

We urge you to enact strong pharmacy benefit manager (PBM) transparency and accountability reforms this year. The undersigned groups strongly support PBM transparency and accountability reforms passed to date by the House and by several Senate Committees this Congress. When taken together, these measures complement and build upon important policy principles that can be found within all of them – commonsense solutions to reorient PBM practices driving better access to lower cost prescription drugs for millions of Americans.

Re: S. 4338 – Pay PCPs Act. GTMRx has submitted formal comments to Senators Whitehouse (D-RI) and Cassidy (R-LA) in response to a Request for Information (RFI) related to the introduction of the senators’ bipartisan Pay PCPs Act, legislation to better support and improve pay for high-quality primary care providers.

On November 8 the GTMRx Institute joined a coalition of employers, health care providers and patient advocates in urging Congress to support strong pharmacy benefit manager (PBM) reforms this year. Needed reforms include commonsense changes to hold PBMs accountable to fair market practices when partnering with our nation’s employers — small, medium and large — who are the largest customers of PBMs. PBM transparency, as with transparency across all healthcare stakeholders, remains one component of the goal to lower costs and ensure access to affordable, quality care. However, PBM transparency alone will not be enough to address the issues employers face in assuring that people covered by employer-sponsored plans are truly receiving the best care at the best price.

Read the entire letter to Senate leadership here.

Re: HHS Notice of Benefit and Payment Parameters for 2024 Proposed Rule, CMS-9899-P RIN 0938-AU97. GTMRx has submitted formal comments to HHS urging the department to adopt as part of the Prescription Drug Essential Health Benefit, medication optimization through the use of comprehensive medication management in all marketplace (Obamacare) health plans. GTMRx is hopeful to begin a dialogue with the Center for Consumer Information and Insurance Oversight (CCIIO) to incorporate CMM in such plans in 2024.

Oral testimony prepared by GTMRx for the North Dakota House Industry, Business and Labor Committee regarding HB 1095 on January 11, 2023.The North Dakota legislature is hearing legislation on codifying comprehensive medication management (CMM) into law. On January 11, 2023, the GTMRx Institute submitted testify in favor of this bill. The GTMRx Payment & Policy Workgroup leadership is working closely with the ND Insurance Commission to support passage into the Senate.

Follow-up Response to CMMI in Reference to the White House’s October 14, 2022 Executive Order on Lowering Prescription Drug Costs for Americans. The Administration is taking immediate action to implement parts of the Inflation Reduction Act of 2022, which will benefit Medicare beneficiaries with a cap for out-of-pocket costs at the pharmacy and for insulin. Combining these changes with CMM services could further reduce unnecessary spending, while increasing care quality.

Follow-up Meeting Letter to Doug Jacobs, MD, MPH, Chief Transformation Officer, Centers for Medicare & Medicaid Services (CMS) on Approaches to Advance CMM and Team-Based, Interprofessional Care

Recommendation Letter to the Agency for Healthcare Research and Quality (AHRQ) on the Person-Centered Care Planning for Multiple Chronic Conditions (MCC) (Document Citation 87 FR 56950)

Recommendation Letter to the Centers for Medicare and Medicaid Services on the Medicare Advantage program (Document Citation 87 46918)

Recommendation Letter to the Office of the Assistant Secretary of Health (OASH) on the HHS Initiative to Strengthen Primary Health Care (Document Citation 87 FR 38168)

Recommendation Letter to the Health Care Payment Learning & Action Network (HCPLAN) on their definition of “accountable care” and the Accountable Care Commitment Curve

Discussion Document on Optimizing Medication Use Through Comprehensive Medication Management (CMM) in Practice: Strategic Recommendations for Implementing CMM into the Care Team with Sustainable Payment and Practice Structures

Sign On Letter of Support to the Personalized Medicine Caucus Co-Chairs—Representatives Tom Emmer (R-MN) and Eric Swalwell (D-CA)—on the Right Drug Dose Now Act 

Recommendation Letter to the Personalized Medicine Caucus Co-Chairs—Representatives Tom Emmer (R-MN) and Eric Swalwell (D-CA)—on the Right Drug Dose Now Act 

Letter to CMS about Payment Mechanisms for Medication Management Services through the proposed Medicare Physician Fee Schedule (CMS-1751-P)

PGx Payment Policy Recommendations from the GTMRx Institute

Letter to the Office of Personnel Management (OPM)’s request for information about OPM Pharmacy Benefits – Notice ID 24322621R0004

Letter to CMS about the interim final rule (effective May 8th, 2020) regarding coverage of medication management services under Medicare Part B (the “IFC”)