Mail-Order

Impedes a health plan’s ability to direct patients to a mail order pharmacy for chronic care medications.

ND – Comment Letter: Proposed Pharmacy Board Rules 61-04-12 and 61-08-01-10 regarding patient counseling services and their impact on mail order pharmacies (May 2016)

PCMA comment letter regarding the proposed changes to Rule 61-04-12 regarding patient consultation requirements and 61-08-01-10 regarding patient counseling services.

PCMA member companies are concerned that the proposed regulations unfairly hinder out-of-state mail order pharmacy practice. For no clear reason, section 61-04-12(3) establishes a separate standard to “provide counseling” to patients who are “required by their insurance plan to use or [are] financially incentivized to use a pharmacy which provides mail-order prescription service.” There is no explanation of the difference between providing “consultation” and providing “counseling” in these circumstances, or what warrants a separate section for patients whose plans provide a financial incentive to use a lower-cost alternative delivery system.

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