Civilian Health and Medical Program of the Uniformed Services (CHAMPUS)/
TRICARE:  Refills of Maintenance Medications Through Military Treatment Facility Pharmacies or Nation Mail Order Pharmacy Program
2015-10-07 2015-08-18 2015-10-05 2015-08-18 2015-09-22
DOD-2015-HA-0062-0008 DOD-2015-HA-0062-0002 DOD-2015-HA-0062-0005 DOD-2015-HA-0062-0003 DOD-2015-HA-0062-0004
04:00:00 04:00:00 04:00:00 04:00:00 04:00:00
https://api.regulations.gov/v4/comments/DOD-2015-HA-0062-0008 https://api.regulations.gov/v4/comments/DOD-2015-HA-0062-0002 https://api.regulations.gov/v4/comments/DOD-2015-HA-0062-0005 https://api.regulations.gov/v4/comments/DOD-2015-HA-0062-0003 https://api.regulations.gov/v4/comments/DOD-2015-HA-0062-0004
Anonymous Anonymous Anonymous Anonymous Anonymous
Anonymous Anonymous Anonymous Anonymous Anonymous
These people who have worked so hard to ensure our freedom should not have to worry about their medications.  This rule is intended to save a few bucks but at what expense?  If our retired military are on maintenance medications they cant afford to miss a day of medications due to any sort of delays ie. snail mail.   Recommend adding the following paragraph under paragraph 5 of Part 199.21 as sub paragraph viii.  All medications not provably known to be chemically stable at temperatures above 150 degrees Fahrenheit will be shipped in climate controlled containers during the months of May through September.  All medications not provably known to be chemically stable below the freezing point of water will be shipped in climate controlled containers during the months of November through March.  Climate control for these medications will be maintained until in the hands of the customer.The FDA only certifies medications to be chemically stable between the temperatures of 59 degrees Fahrenheit and 86 degrees Fahrenheit.  While some pharmaceutical manufacturers have tested their medications and found the climate control is absolutely necessary, many others have not.  UPS trucks and other delivery vehicles in the Southeast U.S. often have on-truck temperatures near the brown sides of their trucks that exceed the boiling point of water.  In the winter, particularly in the North, temperatures well below zero are similarly found in these vehicles.  Medications exposed to these temperatures can change chemical composition and pose grave risk to the consumer, to include the risk of death.  Anecdotal information on mail order pharmacy use in central Alabama has resulted in emergency room visits having been required for some patients as a result of these chemical changes in the heat of summer.  The FDA has the necessary reports on file.  If mail-order pharmacy use is to be directed, precautions should be taken to ensure the medicines shipped in this matter are kept in proper storage from the door of Express Scripts to the door of the customer.Those who have served our military and receive these benefits deserve to know their medications are safe.  Safeguards should be in place to ensure that all medications are kept within or near the FDA recommended temperature range of 59-86 degrees, unless it is absolutely proven that a particular medication can withstand a greater temperature range.  Best Commercial Practices do not do this.  Best Commercial Practices maximize profits, not safety.  Those who have served this country deserve to have their safety put first.  As such, I recommend that the proposed insertion of a sub-paragraph viii (8) with the verbiage above, be inserted into the proposed change to the regulations.   I have concerns that this change while offering some savings to Tricare is only targeting retirees. why arent active duty being targeted as well? This question has to be asked. Just as there is discussion of hardship waivers, why not blanket waivers for say remote duty stations that have no or limited pharmacy access. Active duty has more readily access the the military pharmacies than most retirees as a good portion of active duty reside on the same military installations the pharmacies. Also will additional staffing be provided at the military pharmacies to accommodate the influx of retirees who will be forced to use the base pharmacy because of this rule? i dont see anything posted about this issue. I have concerns that this change while offering some savings to Tricare is only targeting retirees. The question has to be asked why arent active duty being targeted as well? Just as there is discussion of hardship waivers, why not blanket waivers for say remote duty stations that have no or limited pharmacy access. Active duty has more readily access the the military pharmacies than most retirees as a good portion of active duty reside on the same military installations the pharmacies. Also will additional staffing be provided at the military pharmacies to accommodate the influx of retirees who will be forced to use the base pharmacy because of this rule? I see nothing posted about augmenting staffing for the certain influx of retirees. I would like to make the following comments to the interim final rule revisions paragraph (r) to 32 CFR 199.21:(2) Medications covered(iii) It will be cost effective to dispense the medication from the mail order pharmacy.A concerted effort on the part of the mail order pharmacy shall be made to refill all prescriptions, for a patient, at the same time.  All the filled prescriptions shall be combined and shipped in a single container .  I take 10 prescribed meds by mouth each day; Express Scripts cannot seem to fill all orders at the same time, rather they ship each med on a staggered basis (even when all scripts are submitted at the same time) thereby charging TRICARE more for shipping and handling.  My local pharmacy has no trouble filling all the scripts in a single visit for pick up.(5) Procedures.(ii) An effective communication plan that includes efforts to educate beneficiaries in order to optimize participation and satisfaction will be implemented.There must be an administrative channel for feedback as to the service received.  My mail order pharmacy issues many conflicting communications to me and there is no one person to talk to.  One representative says  something that is conflicted by the follow up representative; notification of shipment status is nearly always wrong in that the med does not get shipped as promised and is weeks behind.  I do not know that until I call, then I am informed they have not shipped it yet due to some lame excuse.  My satisfaction and health therefore suffer.  Prior approvals for brand name meds seem to disappear from the system.  My doctors spend a great deal of time writing justification of brand name meds and it appears they are routinely denied.   Denials of prescription medically necessary medications are not signed by a medical doctor or anyone, there must be personal accountability!  Personally, my experience with the mail order pharmacy is that they basically Deceive, Delay, and Deny prescribed meds for military retirees.