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Financial Impact of Alternative Pricing Benchmarks for Physician-Dispensed Drugs in the California Workers’ Compensation System

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Abstract

Background

Pricing drugs in the California Workers’ Compensation System (CAWCS) has become more difficult as there are increasingly fewer drugs listed in the Medi-Cal primary fee schedule, which is used as the source for CAWCS drug prices. This presents a challenge of providing timely and accurate CAWCS reimbursement. The objectives of this study are (1) to explore any trends in physician-dispensed drug prices; (2) to compare the proportion of drugs with and without a price and to determine the financial implications of repricing CAWCS physician-dispensed drugs with five alternative pricing benchmarks; and (3) to offer recommendations for the pricing benchmark to maximize pricing coverage and to remain budget neutral.

Methods

We evaluated physician-dispensed drugs at the transaction level, reimbursed in the CAWCS. Frequency, reimbursement rate, and total and average paid costs were reported. We matched each claim line in the CAWCS to the corresponding unit price of an alternative price benchmark including average wholesale price, wholesale acquisition cost, direct prices, national average drug acquisition cost, and Federal Upper Limit.

Results

Average wholesale price provided prices for 99.9% of physician-dispensed drug claims, while Medi-Cal, the current primary physician-dispensed drug benchmark provided prices for a lower percentage (92.7%) of claims. The CAWCS prices were equivalent to 49% of the average wholesale price, 95.5% of Medi-Cal, 126.7% of the wholesale acquisition cost, 266% of the Federal Upper Limit, 64.4% of direct prices, and 197% of national average drug acquisition cost-estimated prices.

Conclusions

The CAWCS current Medi-Cal pricing for physician-dispensed drugs is better than all alternatives in terms of price availability, transparency, and budget neutrality, but pricing availability may decrease over time as Medi-Cal moves to managed care. National average drug acquisition cost is the next best alternative, but it requires combinations of pricing benchmarks to maximize its price availability.

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References

  1. State of California, Department of Industrial Relations. About us. 2013. https://www.dir.ca.gov/aboutdir.html. Accessed 11 Feb 2016.

  2. Neuhauser F, Swedlow A, Wynn BO. Impact of physician-dispensing of repackaged drugs on California workers’ compensation, employers cost, and workers’ access to quality care: a study for the Commission on Health and Safety and Workers’ Compensation. 2016. http://www.rand.org/pubs/research_reports/RR1560.html. Accessed 27 Mar 2017.

  3. White JA, Tao X, Artuso RD, Bilinski C, Rademacher J, Bernacki EJ. Effect of physician-dispensed medication on workersʼ compensation claim outcomes in the State of Illinois. J Occup Environ Med. 2014;56:459–64.

    Article  PubMed  Google Scholar 

  4. State of California Department of Industrial Relations. Workers’ compensation pharmacy fee schedule: simple prescription. 2016. http://www.dir.ca.gov/dwc/pharmfeesched/pfs.asp. Accessed 16 Oct 2016.

  5. Wilson L, Gitlin M. New workers’ compensation legislation: expected pharmaceutical cost savings. Am J Ind Med. 2005;48:239–48.

    Article  PubMed  Google Scholar 

  6. Swedlow A, Gardner LB, Ireland J. Differences in outcomes for injured workers receiving physician-dispensed repackaged drugs in the California workers’ compensation system. Research Brief, California Workers’ Compensation Institute, Oakland, California, 2013. https://www.cwci.org/research.html. Accessed Mar 2016.

  7. Maiuro L. The Medi-Cal prescription drug benefit: an overview. California Health Care Foundation. 2009. http://www.chcf.org/~/media/MEDIA%20LIBRARY%20Files/PDF/PDF%20M/PDF%20MediCalPrescriptionDrugBenefitOverview. Accessed 11 Feb 2016.

  8. Levinson DR. Replacing average wholesale price: Medicaid drug payment policy. Department of Health and Human Services Office of Inspector General. 2011. https://oig.hhs.gov/oei/reports/oei-03-11-00060.pdf. Accessed 29 Sept 2016.

  9. State of California, Department of Industrial Relations. Workers’ compensation pharmacy fee schedule: simple prescription. 2016. http://www.dir.ca.gov/dwc/pharmfeesched/pfs.asp. Accessed 16 Oct 2016.

  10. California Workers’ Compensation Institute. Workers’ Compensation Claim Form (DWC-1) and Notice of Potential Eligibility, Rev. 1/16. California Workers’ Compensation Institute. https://www.cwciorg/storehtml?si=218. Accessed 9 Mar 2016.

  11. State of California Department of Industrial Relations. Workers’ compensation information system (WCIS). http://www.dircagov/dwc/wcishtm. Accessed 8 Oct 2016.

  12. Tran DM, Lin TH, Wilson L. Value in Health financial impact of alternative pricing benchmarks for physician dispensed simple prescription and administered drugs in California workers’ compensation system, vol. 20, No. 5, May 2017.

  13. Gencarelli DM. Average wholesale price for prescription drugs: is there a more appropriate pricing mechanism? Issue Brief C. Washington, DC: National Health Policy Forum; 2002: p. 775. https://www.nhpf.org/library/issue-briefs/IB775_AWP_6-7-02.pdf. Accessed 29 Sept 2016.

  14. Berndt ER, Newhouse JP. Pricing and reimbursement in US pharmaceutical markets. National Bureau of Economic Research. 2010. http://www.nber.org/papers/w16297.pdf. Accessed 14 Dec 2016.

  15. Schondelmeyer SW, Wrobel MV. Medicaid and Medicare drug pricing: strategy to determine market prices. Cambridge: Abt Associates Inc.; 2004. http://www.abtassociates.com/reports/CMS_Drug_Pricing_Final_Report_Aug_2004.pdf. Accessed 27 Mar 2017.

  16. Messer M. Analyzing drug-pricing mechanisms: pharmaceutical commerce. 2012. http://pharmaceuticalcommerce.com/legal-regulatory/analyzing-drug-pricing-mechanisms/. Accessed 27 Mar 2017.

  17. Center for Medicare and Medicaid Service. Methodology for calculating the national average drug acquisition cost (NADAC) for Medicaid covered outpatient drugs. https://www.medicaidgov/medicaid-chip-program-information/by-topics/prescription-drugs/ful-nadac-downloads/nadacmethodologypdf. Accessed 29 Sept 2016.

  18. Wolters Kluwer. The FUL story: what you need to know about new ACA FUL pricing: clinical drug information. http://www.wolterskluwercdicom/blog/ful-story-what-you-need-know-about-new-aca-ful-pricing/. Accessed 6 Oct 2016.

  19. California Department of Health Care Services. Medi-Cal monthly drug utilization files: ASCII file format. http://www.dhcscagov/dataandstats/reports/Pages/MonthlyASCIIfilesaspx Accessed 8 Oct 2016.

  20. California Department of Health Care Services. Medi-Span electronic drug file (MED-File) v2: clinical drug information. http://www.dhcscagov/dataandstats/reports/Pages/MonthlyASCIIfilesaspx. Accessed 8 Oct 2016.

  21. Wolters Kluwer. U.S. drug price data policy. http://www.wolterskluwercdicom/documents/WKH_AWP_Policypdf. Accessed 4 Oct 2016.

  22. Wolters Kluwer. Federal Government pricing file clinical drug information. http://www.wolterskluwercdicom/drug-data/federal-government-pricing-nadac/. Accessed 9 Oct 2016.

  23. Center for Medicare and Medicaid Services. Pharmacy pricing: federal upper limits (FUL). https://www.medicaidgov/medicaid/prescription-drugs/pharmacy-pricing/index.html. Accessed 17 Oct 2016.

  24. Microsoft Office. Excel 2013 quick start guide. 2017. https://www.supportofficecom/en-us/article/Excel-2013-Quick-Start-Guide-4337FE93-0690-47CB-89A1-8424D5FDD886. Accessed 27 Mar 2017.

  25. Stata Press. Datasets for Stata user’s guide, release 14. 2017. http://www.stata-press.com/data/r14/u.html. Accessed 24 Oct 2018.

  26. Watson C. An in depth analysis of pharmaceutical pricing. Chapel Hill: Gillings School of Global Public Health, Department of Health Policy and Management, University of North Carolina; 2017. p. 1–68.

    Google Scholar 

  27. Curtiss FR, Lettrich P, Fairman KA. What is the price benchmark to replace average wholesale price (AWP)? J Manag Care Pharm. 2010;16:492–501.

    PubMed  Google Scholar 

  28. Academy of Managed Care Pharmacy. AMCP guide to pharmaceutical payment methods, 2013 update. JMCP Supplement 2013; Version 3.0. http://www.amcp.org/WorkArea/DownloadAsset.aspx?id=16476. Accessed 5 June 2018.

  29. Danzon PM. Pricing and reimbursement of biopharmaceuticals and medical devices in the USA. In: Culyer AJ, editor. Encyclopedia of health economics. Amsterdam: Elsevier; 2014. p. 127-35.

  30. Milenkovich N. Physician in-office dispensing of Rx drugs. Drug topics 2014. http://drugtopics.modernmedicine.com/drug-topics/content/tags/controlled-substances/physician-office-dispensing-rx-drugs. Accessed 18 Oct 2016.

  31. Levinson DR. Medicaid drug pricing in state maximum allowable cost programs, executive summary. Department of Health and Human Services, Office of Inspector General. 2013. https://oig.hhs.gov/oei/reports/oei-03-11-00640.pdf. Accessed 27 Mar 2017.

  32. Tag H, Rubinstein E. AMCP guide to pharmaceutical payment methods, executive summary. Academy of Managed Care Pharmacy. 2013. http://www.amcp.org/pharmaceutical-payment-guide/. Accessed 27 Mar 2017.

  33. Lipton B, Laws C, Li L. Workers Compensation Prescription Drug Study: 2013 update. National Council on Compensation Insurance. 2013. https://www.ncci.com/Articles/Documents/II_Prescription_Drugs-2013.pdf. Accessed 11 July 2016.

  34. Wilson L, Turkistani F, Huang W, Tran DM, Lin TK. The impact of alternative pricing methods for drugs in California Workers’ Compensation System: fee-schedule pricing. PLoS One. 2018;13(5):e0197449.

    Article  PubMed Central  CAS  PubMed  Google Scholar 

  35. Cornell Law School. 42 U.S. Code § 1395w-3a. Use of average sales price payment methodology. Legal Information Institute. 2012. https://www.law.cornell.edu/uscode/text/42/1395w-3a. Accessed 5 Jul 2018.

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Acknowledgements

The authors thank Duyen-Anh Pham and Osama A. Shoair for their major contributions.

Author information

Authors and Affiliations

Authors

Contributions

LW obtained funding for the project, designed the study, defined and structured the analysis, and wrote and revised the manuscript. FT conducted the analysis and assisted with the writing of the manuscript. DMT helped design and conduct the analysis and assisted with the writing of the manuscript. WH assisted with the design and structure of the data analysis, and revision of the manuscript. TKL assisted with the design and structure of the data analysis and revision of the manuscript.

Corresponding author

Correspondence to Leslie Wilson.

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Funding

This study was supported by a contract with the California Division of Workers’ Compensation and with data from the California Workers’ Compensation Institute.

Conflict of interest

Leslie Wilson, Gatema Turkistani, Dang M. Trang, Wei Huang, and Tracy Kuo Lin have no conflicts of interest that are directly relevant to the contents of this article.

Data availability

All of the datasets generated during the current study are published in the article and its Electronic Supplementary Material. We purchased our underlying pricing data from First Data Bank and according to our contract with them, we are not allowed to share these data. Some of the Medi-Cal and national average drug acquisition cost pricing data are available on-line, but we used the First Data Bank national average drug acquisition cost and Medi-Cal prices and therefore cannot share our underlying pricing data.

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Supplementary material 1 (DOCX 17 kb)

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Wilson, L., Turkistani, F., Tran, D.M. et al. Financial Impact of Alternative Pricing Benchmarks for Physician-Dispensed Drugs in the California Workers’ Compensation System. Appl Health Econ Health Policy 17, 231–242 (2019). https://doi.org/10.1007/s40258-018-0442-2

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