AP35 - Proposed Rule - Copayments for Medications
Beginning January 1, 2017
2016-02-25 2016-03-07 2016-02-29 2016-02-26 2016-02-24 2016-02-25 2016-03-08
VA-2016-VHA-0003-0005 VA-2016-VHA-0003-0009 VA-2016-VHA-0003-0008 VA-2016-VHA-0003-0007 VA-2016-VHA-0003-0004 VA-2016-VHA-0003-0006 VA-2016-VHA-0003-0010
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https://api.regulations.gov/v4/comments/VA-2016-VHA-0003-0005 https://api.regulations.gov/v4/comments/VA-2016-VHA-0003-0009 https://api.regulations.gov/v4/comments/VA-2016-VHA-0003-0008 https://api.regulations.gov/v4/comments/VA-2016-VHA-0003-0007 https://api.regulations.gov/v4/comments/VA-2016-VHA-0003-0004 https://api.regulations.gov/v4/comments/VA-2016-VHA-0003-0006 https://api.regulations.gov/v4/comments/VA-2016-VHA-0003-0010
Adrienne Lorena William Anonymous Jonathan Tina Anonymous
Esposito Ferrara Witham Anonymous Randall Stockbridge Anonymous
Thank you for allowing comment on AP35 - Id like to take a minute to dissect the new tiered prescription medication program that the VA has proposed to take effect January 1, 2017. I am against a tiered medication program. Tier 2 medication costs will not change from the $8.00/$9.00 cost, however 35% of medications will be put in this classification vs every medication currently prescribed (100%). Tier 3 Includes medications that retain patent protection and exclusivity and are not multi-source medications. 15% of medications utilized by veterans fit in this categoryThe result is an inadvertent penalty for veterans who are benefiting from the newer medications still under patent, the veterans who are sickest and have no other options for treating their medical conditions using the rational of name-brand/patented medications being more expensive outside of the VA. This is purely a cost-recovering measure for the VA at the expense of the veteran. The issue of raising costs on the effect of complianceRaising the co-payment may create a situation in which veterans pick and choose which medications they will fill based on $11.00 vs $5.00 rather than the blanket $8.00/9.00 currently charged. A veteran can get two Tier 1 medications filled for $10.00 vs. one Tier 3 for $11.00.Table 1 Table 1 is an example of yearly costs of tiered medications, current regulation, and potential annual savings. Again, we find that the veterans with no option other than patented, Tier 3 medications will pay twice plus the amount of copay per year than those who can be treated with Tier 1 medications. Typical User of Tier 1The VA states that the veterans saving the most through this new tiered program are those using Tier 1 generic medications. Referring again to Table 1, the typical user of Tier 1 medications will pay, by estimates, $150.00 per year at $5.00 per medication compared with the current $240.00 per year at $8.00 per medication. Let me tell you why I feel this is a cost comparison that is defraying another issue veterans have with the VA prescription service: At Walmart, a 90 day supply of selected generic prescriptions is $10.00. At the VA, a 90 day supply of Tier 1 generic is $15.00.  $20.00 difference per year for three Tier 1 medications is $60.00 more than patrons of Walmart. For two Tier 1 medications, it is a yearly cost of $40.00 more than Walmart patrons will pay. I find it hard to believe that the VA has less bargaining power with pharmaceutical companies than Walmart. I also find it hard to believe that Walmart appreciates its customers more than my country appreciates my military service. Thank you for allowing me to comment on an issue that will affect hundreds of thousands of veterans.  comments enclosed.  I have just read the proposed rule and I believe it to be fair and equitable, I like the tier levels to establish  the co-payments, how ever I do think there needs to be a pool of emergency funds that a Veteran can use each year if they are unable to afford their co-payment. It can be set up so they have a certain amount of times they could use this fund.  But I do believe that any Veteran that was in a war or conflict or has served over 20 years should be covered 100% no co-payments at all. This looks like it will be a great way to help veterans have more affordable prescriptions while maximizing the quality of treatment they receive. However, I feel that in (b)(2)(i)(E) if 40% of veterans are experiencing hypertension, that hypertension medication be included in the service connected medications, and therefore exempt from payment. I think that this rule will help Veterans. My reasoning for this is because most medication you receive from the VA is generic medication. However, not all medication has a generic counterpart, therefore resulting in higher prescription costs. The new rule with the tiers will allow veterans to get the proper medication and not have high out of pocket costs.  I am opposed to this rule because the VA is still expecting our veterans to pay more for their prescriptions medications than they would pay if purchasing them through a non VA pharmacy. It is time for us to be more generous to our veterans and live up to our duty to support them after they made an oath to give their life to defend our country. Lets offer them the same rate that they would receive in civilian pharmacies.  BIO comments on Copayments for Medications Beginning January 1, 2017.