letter to HHSC Commissioner re: Vendor Drug Program

December 18, 2013

Dear Executive Commissioner Janek,

This letter is in regard to Vendor Drug Program changes that are being considered as a result of savings required by HHSC Rider 51. The Texas chapter of the National Alliance on Mental Illness (NAMI) Texas and our 28 affiliates around the state have some concerns about this process. Our concerns includes:

• Clinical edits that could negatively impact access.
• Restrictive agreements in which drug companies give the state greater rebates if the state restricts access to competitor drugs.
• Eliminating grandfathering for drugs used to treat mental illness.
• Shrinking the Preferred Drug List (PDL), Antipsychotic Class.

These potential changes are concerning to NAMI Texas for the following reasons:
• Open access to psychotropic medications ensures that physicians can prescribe the most appropriate therapy for patients based on the patient’s unique and individual needs.
• When physicians are treating patients with mental illness, they must carefully match the individual needs of the patient to the varied characteristics of the different available medicines.
• Studies have shown restrictive policies may actually increase costs, such as partial hospitalizations, emergency mental health services, and nursing home use. And more importantly, such restrictions may contribution to an increase in patients’ pain and suffering.
• When treating mental illness, it’s important to know that each individual responds differently to different medications. Because of these differences, getting to the right treatment is a process. It often takes trying several different medications, at different doses, before a patient reaches a proper level of treatment.

According to the National Survey on Drug Use and Health, in the past year 4.5% of Texans experienced serious mental illness and 18.4% experienced any mental illness. The National Institute of Mental Health reports that 26.2% of adult Americans, or nearly 5 million Texans, have a diagnosable mental illness. A large population of Texans stands to be negatively affected by some of the proposed Vendor Drug Program changes.

If the decision is made not to reverse moving various antipsychotics off the Preferred Drug List, please at least consider not removing the grandfathering for patients who are stable on these drugs.
• Any patient that is stabilized on an existing medication should be exempt from any newly imposed restrictions placed upon that medication – it is not appropriate to force stabilized patients off of their medications.
• Maintaining stabilized care is not only cost-effective, but also crucial to individual health outcomes. Due to the vulnerability of the Medicaid population, it is important that stabilized care continue.
• Many of the Medicaid patients treated by these drugs take more than one medication and have likely been on the same medication regiment for years. Thus, creating barriers to appropriate medicines could adversely affect these patients.
• Preserving the physician-patient decision-making authority should be the focal point for all decisions regarding drug treatment regimens. Patients whose treatment is decided based on cost alone may not receive the best treatment for them, and consequently result in requiring more costly treatment in the short- and long-term, including emergency hospitalizations and in-patient care.

NAMI Texas did hear from the family of a person with bipolar disorder who is concerned about their loved one being moved off Seroquel XR. More time is needed to understand how this potential change in medication intake would affect the individual’s clinical outcomes. Please consider delaying the decision to move Seroquel XR off the Preferred Drug List in order to allow a chance to re-review Seroquel XR at the next P&T meeting.

Thank you very much for reviewing this letter and considering the recommendations of NAMI Texas.


Greg Hansch
Policy Coordinator, National Alliance on Mental Illness (NAMI) Texas


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