Employers: doing the work
Finally, employers are becoming increasingly collaborative with PBMs and third-party vendors in helping workers to take proactive
approaches to health and to understand what's prescribed to them. Beyond providing co-pay relief to spur adherence, companies
now find ways to encourage workers and their families to visit their physician at least three times a year, and to ask questions
about prescribed medications. As Larry Boress, President and CEO of Midwest Business Group on Health (MBGH) explains, "We
want to make sure doctors are prescribing the appropriate drug. What are the side effects? How can it help them, and why is
it important to stay on it and remain vigilant in refilling it?"
Employers may work with PBMs and health plans to ensure medications are being filled and taken as directed, as PBMs often
know quickly when someone has filled their prescription. In considering the role of the pharmacy, companies also consider
coaching programs whereby they offer employees the opportunity to work with a pharmacist. For instance, MBGH has a program
where an employer may offer employees reduced or waived co-pays for diabetic drugs if the person agrees to see a specially
trained pharmacist a minimum of four times a year for monitoring, management, education, and adherence support.
However, while some employers have made progress, most do not set their expectations for the vendors, even though they know
better. "The employers view themselves as knowing they have a role, but often times they don't have the support or the information
to do that. In understanding how to work with these HIPAA-compliant third parties, companies can ensure that they can impact
the issue of adherence."
A member of MBHG's board, Abacus Health Solutions is one such third party making waves in the space today. Its voluntary,
value-based program incentivizes employees who regularly visit their physicians. By mining and analyzing data provided by
health plans, Abacus monitors participation to reward compliant employees with reduced or nonexistent co-pays, especially
in the case of chronic conditions such as diabetes. The company also evaluates claims data to determine conditions the patient
may have and effectively assess outcomes. In engaging directly with physicians, Abacus stages interventions with particularly
non-compliant patients to help employers avoid bearing any risk associated with higher premiums.
To be continued...
The win-win scenario of simultaneously driving down costs while improving outcomes has put new life into adherence and serves
as a guiding light to many organizations who have struggled in the past to see its significance. Nevertheless, while these
new stakeholders, technology innovators, and the public health community continue to dream up new ways to inform and engage
patients in the hopes that they'll fill and maintain their drug regimen, evolving regulatory pressures both inform and challenge
the next steps forward.
Privacy, for one, continues to be a concern. Recently, CVS announced it would not be continuing its practice of mailing prescription
refill notices to consumers on behalf of pharma companies, citing modifications to HIPAA's new omnibus rule effective in September.
The rule generally forbids any parties covered under HIPAA to send information to consumers about a third party's services
This issue of what people and regulators will and will not accept is still being discussed as the environment of big data
evolves, and as EHRs and Accountable Care Organizations (ACOs) slowly become institutionalized. Some pharma companies have
already begun discussing EHRs as an opportunity to market adherence programs to physicians and patients. In providing one-touch
solutions on EHRs for doctors to send patients information on drugs and conditions, companies can be perceived as making a
dent on compliance to medication regimens and overall health outcomes. ACOs are hiring pharmacists to help educate staff in
helping to facilitate more medication adherence on behalf of patients. But as both ACOs and EHRs are in their early phases,
companies will have to wait for the hammer to come down fully before moving forward with large-scale visions.
It is therefore easy to see why pharma companies are finding it tougher to know where to stand in an environment that is still
under construction. Much of the concern centers on how to stoke the fires of dialogue online and elsewhere without igniting
a regulatory inferno, through an inadvertent bump up in adverse event reports and other publicity that burns brand reputation.
The big question is will there be a respite when the FDA comes forward at year-end with final guidelines on appropriate mHealth
Clark Herman is Pharm Exec's Associate Editor. He can be reached at firstname.lastname@example.org