Civilian Health and Medical Program of the Uniformed Services (CHAMPUS)/
TRICARE:  TRICARE Retail Pharmacy Program
2012-07-26 2012-07-10 2014-11-21
DOD-2012-HA-0049-0004 DOD-2012-HA-0049-0002 DOD-2012-HA-0049-0007
04:00:00 04:00:00 05:00:00
https://api.regulations.gov/v4/comments/DOD-2012-HA-0049-0004 https://api.regulations.gov/v4/comments/DOD-2012-HA-0049-0002 https://api.regulations.gov/v4/comments/DOD-2012-HA-0049-0007
Anonymous Anonymous Anonymous
Anonymous Anonymous Anonymous
My comment is that the change has benefits and disadvantages, not only to the military personnel but to those that service them.  In particular the proposal to automatically place newly approved drugs by the FDA into tier 3 category without prior review from the PT committee will not only cause a financial hardship to those paying the exorbitant cost sharing to pharmacies but it also delays intended prescribers from any new medications.  As an associate in the pharmaceutical industry this change affects how our case managers conduct pharmacy benefit investigations for drug coverage, and how we train our associates to manage prescriber and patient expectations when reporting benefits. This change in regulation will also affect our manufacturers and their ability to provide financial assistance to families that cannot afford to pay their copayments.  I wish to have them reconsider this portion of the new rule or to allow manufactures the option of providing support to families that cannot afford their copayments.  I think that this action is good but it will cause a financial burden with patients on certain medicines that may be changed by a physicain due to a need to control the illness or disease with new medications. This may cause more out-pocket expenses. How will a patients interest be protected by having a medication left over and purchasing a new prescription? This will be a out-pocket expenses that they accrude will cause even more problems when facing coverage gap. Although not the intended subject of this proposed rule, the status of reimbursement for compounded drugs under TRICARE is currently a topic under review.  With that in mind, I am commenting on the proposed revisions to 32 CFR 199.21(h)(3)(i).  If compounded drugs are classified as Third Tier, or non-formulary drugs, retail pharmacies could be precluded from providing such drugs to TRICARE beneficiaries and such patients could be required to obtain these drugs from the TRICARE mail order pharmacy if the Department of Defense Pharmacy and Therapeutics Committee recommends limiting access to compounded drugs to the TRICARE mail order pharmacy only.  That recommendation would have to be based on determinations that there is no significant clinical need and there is a significant additional government cost for access in both mail order and retail pharmacies, and such recommendation must be approved by the Director of DHA.I am concerned that the ability to eliminate retail pharmacies from providing allowed compounded drugs would significantly restrict, and perhaps eliminate, the access of TRICARE beneficiaries to compounded medications.  Such a determination would leave the TRICARE mail order pharmacy as the sole source for compounded drugs.  It is unlikely that such a pharmacy has the expertise to safely prepare the wide variety and complexity of all compounded drugs prescribed.  If a prescribed compounded drug is covered under TRICARE, the TRICARE beneficiary should not be prohibited from receiving that drug due to limitations imposed based on the inability of the TRICARE mail order pharmacy to safely prepare such compounded medication.  For this reason, if the regulation must be revised to allow designation of a single point of service in order to comply with the statute, that access point should be the retail pharmacies.    