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Market Access Strategic Execution Consultant

Krishna Patel

Freelance Market Access Strategic Content Developer

CMS Final Rule Threatens Existence of Manufacturer Coupons

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CMS Final Rule Threatens Existence of Manufacturer Coupons

Peter Pitts and Jason Zemcik wrote a brilliantly simple article later last week dissecting the CMS Best Price Rule.

Manufacturers offer copay assistance coupons for many drugs in order to offset cost share. Evidence from a Massachusetts Health Policy Commission study suggests that these coupons indeed promote adherence and better outcomes.

Unfortunately, a critical drug pricing rule finalized by CMS towards the end of 2020 could unintentionally jeopardize coupons. The rule requires that manufacturers ensure the benefit of their coupons go solely to the patients. If the coupon’s full value is not realized by the patient, the manufacturer will be required to count it as a discount to the drug’s Medicaid price (manufacturers are required to give Medicaid programs their ‘best price,’ which is the lowest price they offer to any other purchaser of a drug).

How could a coupon possibly benefit anyone else other than a patient? Payers have figured out how to flip coupons on their head in order to remain profitable. Copay accumulators. Under the copay accumulator tactic, the coupon value is not counted against the deductible. Therefore, once the coupon funding is exhausted, beneficiaries are forced to pay their full deductible. When faced with this situation, many patients are forced to decide between paying their rent/mortgage or seeking medical care.

In this accumulator scenario, coupons can be viewed as a price concession to an entity other than a patient since it lowers payers’ cost for the drug. As a result, CMS would require the full coupon value to be factored into Medicaid discounts.

If the best price is brought down further with coupon values, how likely is it for manufacturers continue offering coupons?

If they are forced to thus stop offering coupons, how will this impact patient access to necessary treatment?

Lexus Came From Toyota Embracing Conflicting Goals

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Lexus Came From Toyota Embracing Conflicting Goals

If the market demands conflicting outcomes, embrace it (before someone else does).

The market is demanding health care delivery that is affordable + effective—highly conflicting priorities!

Harvard Business Review narrated a successful case of embracing conflicting goals:

‘When designing what became the Lexus line, Ichiro Suzuki, Toyota’s chief engineer, stipulated that the new car needed to be faster, lighter, and more fuel efficient than existing luxury sedans. The order was full of contradictions. Making a car faster usually meant having a bigger, heavier engine; making it lighter without compromising power meant stripping out luxury that was essential for this segment. So, the Lexus team returned to fundamentals and re-evaluated their most basic assumptions about how to build a car. Alongside tens of smaller new ideas, they designed and built a first-of-its-kind aluminum engine that made the car 120 pounds lighter, improving weight and fuel efficiency, thereby delivering on a seemingly impossible demand.’

Right now, all eyes are on payers and PBMs. What are they doing to make health care affordable + effective? Drugs are only effective is they’re used for the right patients at the right time.

I Must Govern the Clock, Not Be Governed by It

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I Must Govern the Clock, Not Be Governed by It

‘I must govern the clock, not be governed by it.’  –Golda Meir

Golda Meir lived for a single goal that was impossible to achieve. All of her efforts were for this particular goal. She achieved it.

In the process, she set an example for what a person in control of her situation is capable of:

  • Valedictorian despite being poor
  • Wife
  • Mother
  • Signer of Israeli Declaration of Independence
  • Prime minister
  • Iron Lady of Israeli politics
  • Personally visited families of soldiers killed in battle

…and yes, she was a woman.

Flying Together

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Flying Together

Once a hunter cast a net over a flock of birds busy pecking at grains. Flustered, the birds scrambled to escape in every direction—but in vain. Until a wise leader amongst them said, ‘We can still escape. Stop trying to fly in all directions. All of you fly in this direction,’ as he pointed up. ‘One, two, three!’ As ordered by their leader, the birds took off together. And they took the net with them.

How many birds needed to move upwards in order for this escape plan to work? ALL. Could any single bird have managed to escape alone? Absolutely not.

There is an important lesson about teamwork in this kids’ story. Think about the laggards in your team. A team is only as strong as the weakest person.

By definition, humans make mistakes (otherwise we wouldn’t be humans, we would be God). We’re in this together.

Even if they don’t have the self-confidence to say, ‘today I’m going to do the best job,’ I don’t believe anyone intentionally comes to work saying, ‘today I’m going to do a terrible job.’

We can all benefit from encouragement and upliftment.

Catch 3 people doing something right everyday (and I don’t mean false praises). Challenge yourself to do this for a month. This is the posture of good-finding. Blaming undoes us, whereas good-finding nourishes us (both the person on the giving as well as receiving end).

Pandurang Shastri Athavale (my friend, philosopher, and guide) puts it very simply: ‘The other is not another, he is my Divine brother.’

How can we all fly upwards TOGETHER (because we NEED to fly together)?

Ensure Preapproval Information Exchange (PIE) Is On Time

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Ensure Preapproval Information Exchange (PIE) Is On Time

AMCP held an insightful webinar on preapproval information exchange (PIE) in June 2020. I encourage you to check it out.

Lisa Cashman (Director of Clinical Account Services, MedImpact Healthcare Systems), Laura Randa (Vice President Market Access, HEOR and Public Policy, Mycovia Pharmaceuticals), and Jay Jackson (Senior Vice President, Consulting, Xcenda) shared generous insights on payers’ perception of preapproval information exchange (PIE).

Payers want information as early as possible because they might make budgeting decisions a year-out—up to 25% of payers initiate this process 18 months from launch (depending on their plan size). The information they want can broadly be categorized into 3 buckets: volume, patient profile, and cost.

Unfortunately, many PIEs occur too late to be useful for this purpose.

The panelists suggested the following timeline:

  • 18-12 months from launch: communicate indication, development plans, preliminary data, epidemiology, and disease information
  • 3-6 months from launch: keep the conversation going by providing updates and pricing information (to the extent that you feel comfortable sharing)
  • Leading up to launch: begin engaging in health care economic information exchange

Respect Time if you want your investment to work for you.

‘If you’re early, you’re on time. If you’re on time, you’re late. If you’re late, [hopefully you’re not dead. Because if you’re still alive, you get a second chance].’

When do you engage with payers in PIE?

Your Customers Should Feel Heard

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Your Customers Should Feel Heard

Everyone has a problem.

Believing that your customers have no problems is just as true as believing that everyone posting smiling photos on Instagram has no problems.

What’s the problem of your customers? What keeps them up at night? What makes it dreadful for them to come back to work the next day? Why are they right to think this way?

The sequel to this would be: How can you show up to delight them? But let’s not get ahead of ourselves. 

Customers feeling like they’re heard is in itself a TREMENDOUS stride forward.

Nurture trust. Nurture relationship.

If your neighbor knocked at your door with freshly baked cherry pie, would you accept it? What if a stranger did the same thing: would you accept it?

Dance With the Struggle

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Dance With the Struggle

The J Curve has come up in several of my conversations over the past couple days. I first learned about it in Thanks for the Feedback: The Science and Art of Receiving Feedback Well.

The journey towards a goal is not a straight upward line, but rather a J curve.

When tracing the letter ‘J,’ we start in the middle>>dip down>>then swing back up to the top.

The Dip (also called the Valley of Death by some sources) is inevitable in the J curve. The dip is when we feel the struggle and discomfort. It’s in the dip where the majority quits. The deeper/wider the dip, the more likely it is that people will give up and go home.

Be ready for the Dip. When it arrives, do not run away. Tell it, ‘I’ve been waiting for you—there you are.’ Embrace the pain. Lean into the Dip in order to come out the other end. Dance with the struggle.

Once I saw the J curve, it was hard to un-see it. It’s everywhere: career development, relationships, spirituality, education, physical fitness, learning a new skill, sales, manufacturing, distribution….

It’s easy to be a CEO. What’s hard is getting there.

You do 8 reps in weight training so that you can get the benefits from pushing through the last 2.

Staying in the game is magical.

When you face the Dip, how do you stay in the game?

Keep the ‘Exchange’ in ‘Preapproval Information Exchange’

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Keep the ‘Exchange’ in ‘Preapproval Information Exchange’

Preapproval information exchange (PIE) has become among pre-launch strategies since the update to FDAMA 114 in 2018.

Most of us have figured out that it’s important for a launch strategy to include PIE. However, I’m wondering how many of us take FULL advantage of these opportunities to engage with payers pre-launch.

HBR published an interesting article earlier this week suggesting that important consumer insights can be gained from unexpected opportunities like crowdfunding.

Here’s an excerpt: ‘Crowdfunding is not only a source of financing for start-up companies, it’s also a potentially powerful tool for big companies looking for customer input during product development because CUSTOMERS WILLING TO PUT MONEY INTO DEVELOPING A PRODUCT ARE GOING TO BE MORE ENGAGED THAN PEOPLE IN A FOCUS GROUP. Companies that use crowdfunding in this way should pay particular attention to the input of atypical customers.’

Back to PIE: striking a bi-directional conversation during a PIE engagement is key during the pre-approval stage. It’s an important opportunity for manufacturers to get feedback from the customers that will be paying for their assets. This group is possibly more engaged than people in a focus group.

How can your PIE deck be engineered to facilitate a bi-directional EXCHANGE of information rather than a one-way information dump?

Here’s a brilliant recommendation from Nancy Duarte in HBR Guide to Persuasive Presentations:

‘Develop a clear, short overview of your key points, and place it in a set of executive summary slides at the front of the deck; have the rest of your slides serve as an appendix. Follow a 10% rule of thumb: If your appendix is 50 slides, devote about 5 slides to your summary at the beginning. After you present the summary, let the group drive the conversation. Often, executives will want to go deeper on the points that will aid their decision making. You can quickly pull up any slides in the appendix that speak to those points.’

What kind of consumer insights do you want to gain during this preapproval information exchange? How can PIE be used to gain these insights? How will you ensure the feedback gained during the PIE engagements reaches the right people that will act on it?

Meal Planning Saves Projects

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Meal Planning Saves Projects

I have nothing against eating out. Except when I INTEND to have a homemade meal, but it’s already dinnertime by the time I finally decide what to make.

The archenemy of homecooked meals in the Patel household is not its complexity, unavailability of ingredients, or lack of time—it’s the surprising culprit of indecision.

Meal planning helps because it’s a TEMPLATE that solves my single biggest obstacle to homemade meals.

Templates work. They establish boundaries backed by science.

Market access projects are as much science as they are art. When engineered by experienced professionals, templates make the science part straightforward.

Templates can take on many forms. Useful templates are simple yet profound. Questions that MUST be answered before diving into projects. Items that MUST be checked-off before handing over projects to Clients.

Once the science part is taken care of, the fun part begins: making art.

What are the most common reasons for project failure? Failure of specific PARTS of a project? How can you flip these obstacles on their head?

Do Your Best. It’s Good Enough Around Here

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Do Your Best. It's Good Enough Around Here

‘Do your best. It’s good enough around here.’

There are 2 reasons I like it when we say this.

First, it takes off the pressure of expectations. The release of this weight in itself improves performance. 

Carefree is important. Carefree is not the same as careless.

Secondly, it’s a shortcut to getting in touch with my Self that cuts through the noise. I hold no one else accountable for my actions except myself. This is my chance to see what I can really do. It’s a journey of Self discovery that makes me feel focused, clear, and alive.

I give it my all–so much that I can look God in the eye and say, ‘I did my best–now it’s Your problem.’

How do you strive to set your personal records?

Krishna Patel, PharmD
Market Access Strategy and Execution Consultant
info@sojusllc.com
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