At the end of November, CVS Caremark released Amendments to its 2018 CVS Caremark Provider Manual that is given to pharmacy providers nationwide to give a heads up in changes to the provider agreement. Many 340B members have been in communication with 340B Health because of the severity of these changes.
One of these two Amendments states that any pharmacy participating in 340B (chain, individual pharmacy within a chain and independent pharmacy location or a pharmacy owned by a 340B covered entity) can be subject to a denial of a PBM rebate by a manufacturer on 340B prescriptions as those scripts are not considered a retail pharmacy prescription. CVS also states that “Caremark reserves the right to apply unique terms and conditions to such provider’s participation in any retail network(s) in which the provider is participating.”
The other Amendment was sent to Covered Entity owned retail pharmacies stating “[The] pharmacy has been identified as a pharmacy owned by a 340B Covered Entity and is therefore no longer qualified to receive reimbursement using CVS Caremark’s standard commercial pharmacy reimbursement rates.”. These new, lower reimbursement rates will impact most commercial networks except for Medicare part D scripts. These cuts are set to take effect Feb. 1, 2019, and will only affect Covered Entity owned retail pharmacies.
340B is currently taking action of these new amendments by:
- Reaching out to senior leaders at CVS Caremark to gain additional insight into these policies and seek their reversal;
- Evaluating alternative options for addressing the issues, including federal advocacy; and, we are asking all of our member hospitals to complete a short online survey to let us know if you have received any of these correspondence from CVS Caremark and share some important information to assist us in addressing this issue.
PHV has started to reach out to their members/clients to see if they have received any amendments from CVS. If your entity or pharmacy has received news from CVS, please reach out to Andrew Cross at Andrew.firstname.lastname@example.org or at 402-742-2211.