Missouri Letter [RE: State Maximum Allowable Cost for Blood Clotting Factor Products]

August 28, 2014

VIA U.S. MAIL & EMAIL

Ms. Rhonda Driver, R.Ph.
Director of Pharmacy
MO HealthNet Division
615 Howerton Court
PO Box 6500
Jefferson City, MO 65102-6500

RE: State Maximum Allowable Cost for Blood Clotting Factor Products

Dear Ms. Driver:

I am writing to you on behalf of the State Patient Access Coalition which is a coalition of nation’s top specialty pharmacies and the world’s leading manufacturers of blood clotting factor. We are concerned about recent changes to Missouri Medicaid’s reimbursement for blood clotting factor products.

The reimbursement changes effective July 14, 2014, are significant reductions in reimbursement. My calculations show that reimbursement has dropped almost 35% for some products when compared to the four quarters of reimbursement for 2013.

We think it is noteworthy that the Missouri Medicaid Pharmacy Manual states in the Reimbursement Section, “The Division establishes a rate of payment that ... ensures access to quality medical care for all participants by encouraging a sufficient number of providers.” The recent reductions in Missouri’s blood clotting factor reimbursement are such that a significant number of providers are being paid less than their acquisition costs. We do not believe this “rate of payment ensures access...by encouraging a sufficient number of providers.”

Further, 42 U.S.C.Section 1396(a)(30)(A) requires state Medicaid programs to adopt payment rates that “are sufficient to enlist enough providers so that care and services are available under the plan at least to the extent that such care and services are available to the general population in the geographic area.” We suggest that Missouri Medicaid will have a difficult time meeting this federal standard with the recently implemented reimbursement rate.

Because of our patient access concerns, we ask that you retroactively return to your 2013 rates or some other rate that will meet the federal and state tests described above. We thank you for your consideration of our concerns. I am happy to answer any questions or comments you may have on the matter. I may be reached at 443-433-0900 or This email address is being protected from spambots. You need JavaScript enabled to view it.. Also, if possible, we would welcome the opportunity to meet with you about our concerns.