On January 21, 2016, the Centers for Medicare and Medicaid Services (CMS) published the federal Covered Outpatient Drugs Final Rule (CMS-2345-FC). The intent of the federal regulation is to address the rise in prescription drug costs by ensuring that Medicaid programs reform payment methodologies for prescription drugs and to ensure drug rebates accurately account for market prices. The regulation requires all states to be in compliance with the rule by April 1, 2017. The Wisconsin Department of Health Services (DHS) is actively engaged in developing an implementation plan to comply with the rule and is committed to working with the Pharmacy Society of Wisconsin (PSW), National Association of Chain Drug Stores (NACDS), and Wisconsin pharmacies to ensure those most affected have an active voice in the process.

Since DHS is required to change its pharmacy reimbursement policy as a result of the federal rule, DHS is conducting a survey of pharmaceutical dispensers to obtain data for pricing professional dispensing fees. DHS cannot stress enough how critical it is for pharmacies to participate in this survey, as the data collected will be a main factor in how the professional dispensing fee is determined. There are approximately 1,600 Medicaid-enrolled pharmacies in Wisconsin and it is crucial that DHS receives a good representation of data from all the types of pharmacies. Participation in the dispensing fee survey is mandatory for all Medicaid-enrolled pharmacies.

DHS has retained Mercer to assist in the implementation of a cost of dispensing survey. Prior to sending out the survey, DHS will be collecting contact information for all Medicaid-enrolled pharmacies. The cost of dispensing survey process will include the following steps:

• DHS will be contacting pharmacies in the upcoming two weeks to gather point of contact and demographic information in preparation for sending the dispensing fee survey. For example, if an individual store has a corporate entity that will complete the survey on its behalf then we would like the corporate contact information.
• A survey to obtain information on Wisconsin pharmacy-specific dispensing related costs, as defined by CMS, will be sent to all Medicaid-enrolled pharmacies after we have gathered all contact information. Pharmacies will be given three weeks to respond to the survey.

DHS looks forward to working with Wisconsin pharmacies and will keep PSW, NACDS, and pharmacies informed throughout the process. DHS will continue to work directly with provider associations to conduct stakeholder meetings and receive feedback on reimbursement changes as a result of the final rule.

DHS has created the ForwardHealth Portal Covered Outpatient Drug Pricing page.

This Portal page will be the repository for outpatient drug rule information. Pharmacies are encouraged to check this page regularly for updated information. Additionally, pharmacies are encouraged to sign up for the Outpatient Drug Rule email subscription option in order to receive important updates.

Providers should send any questions or comments on the upcoming professional dispensing fee survey to CODSurvey@mercer.com.