We are writing this letter to express our concerns with the newly implemented Geisinger 90-day Managed Care mandate. The pharmacy contract that the Department of Human Services approved with Geisinger Family Health Plan has had a devastating effect on Medicaid patients, tax-payers, and independent pharmacies of Pennsylvania. This contract has granted Geisinger the ability to mandate patients receive a 90-day fill of a prescription unless they go through a complex exception process. This contract is both irresponsible and inappropriate for many of the Medicaid recipients we service. Moreover, it is wasteful of taxpayer money and it is obliterating independent pharmacies due to the drastically below-cost reimbursements that are tethered to the dispensing of 90-day medication supplies.

Providing substantial amounts of prescription pills to a patient, if not absolutely necessary, is dangerous and it is unreasonable to believe that this mandate will not have damaging outcomes. Managing monthly medications can be a very difficult task and tripling a patient’s medication supply, via this mandate, will only further complicate the issue. Furthermore, through our first-hand experience, we have noted that dispensing a 90-day supply of medication actually reduces adherence due to the elimination of monthly medication counseling that a pharmacist typically provides. Interacting with our patients once every three months, rather than monthly, will eliminate our ability to communicate effectively with our patients and eradicates our ability to maintain close relationships with them. The relationships that we build with patients are often the driving force behind the quality of their overall health.

In terms of patient safety, pushing for patients to receive 90-day supplies will inevitably increase the chance of accidental ingestion and/or overdose whether it be by the patient, a friend or family member, or even a child who inadvertently gains access to them. Drug Take-Back days are strategically utilized for the purpose of removing excess medications from the streets and peoples’ homes. This push for 90-day supplies will have the exact opposite effect of Drug-Take Back days. As independent pharmacists who know our patients, we are warning that this has serious potential to result in more fatal outcomes. In this case, the potential risks associated with this mandate far exceed the potential benefits. It is not socially responsible.

Additionally, the 90-day medication fills are wasteful of taxpayer money. Patients consistently have medication regimens changed or discontinued. Therefore, if we dispense a 90-day supply of a medication to a patient, the state taxpayers will be invoiced regardless of whether or not the patient is instructed to stop taking that medication prior to finishing the provided 90-day supply. Patients also often misplace their medications, accidentally drop them, etc. With 30-day supplies, we have a fairly minimal stop-loss that effectively limits unnecessary costs incurred by our healthcare system when replacing lost, stolen, or damaged medicines. With a 90-day supply, we are tripling that stop-loss. It is not economically friendly to our state.

Lastly, independent pharmacies are being under-reimbursed up to hundreds of dollars below our acquisition cost for any 90-day supply of a brand-name medicine. Pennsylvania thrives off of independent pharmacies. We offer services that chain pharmacies fail to offer such as free delivery, house charge accounts, and pill packets. Without these services, many patients will not have access to their medications, adherence rates will drop significantly, and collectively our overall health will decline.

After serious public back-lash from independent pharmacists throughout Pennsylvania, Geisinger decided to offer three exception options:

1. The prescriber may file a pre-authorization to utilize a 30-day fill, however this places a burden on an overly taxed medical community;

2. The patient may file a special request, which is confusing and time consuming;

3. The pharmacist may submit a computerized fill history showing non-compliance which is complex and inefficient. But much of the reason the Medicaid recipient has been compliant is due to the help of the pharmacist every 30 days. If Geisinger truthfully believed that a 90-day fill would increase adherence, then why would they only permit a pharmacist to opt-out non-adherent patients? It makes no sense. Under their belief, it would only make sense to allow adherent patients to opt-out.

This new push for 90-day supplies is strictly profit driven. Geisinger and their contracted Pharmacy Benefit Manager, Med-Impact, stand to financially gain significant dollars through this program.

If this policy is not revised immediately, it will have the following series of instantaneous catastrophic outcomes:

• It will unnecessarily put Pennsylvania’s most vulnerable Medicaid recipients at high risk;
• Healthcare costs will increase to the state Medicaid program as a result of wasteful spending;
• It will indisputably decrease patient adherence due to the limitations it places on community pharmacies and our pharmacists ability to interact with and counsel patients on a monthly basis; and
• Community independent pharmacies of our Commonwealth will be driven out of business resulting in the loss of thousands of jobs

In conclusion, we are strongly advising against this 90-day supply mandate and we urge you to contact DHS and encourage them immediately cease and desist on this and retract their approval of the program. It is unsafe, it is irresponsible, it is wasteful, and it will have tragic long-lasting effects on our great State of Pennsylvania.