In this era of high tech and big data, administrative surveillance of rebate programs by payers, aggregators and manufacturers has been enabled to unprecedented levels of micromanagement. Purchasers of rebate aggregator services should not be an exception to this process.
Painstaking though it may be, due diligence in the contracting process will yield dividends in the long run. It cannot be emphasized enough that electronic formulary and rebate management platforms are essential tools to maximizing rebate performance. The amount of detail necessary to support informed decision making for formularies includes economic as well as clinical information. Having real world net cost information readily available is invaluable in the success of these programs.
With the growing interest in consumer point of service rebates, developing these capabilities to support client benefit options adds another important consideration to rebate revenues and the timeliness of funding needed to support these POS rebate programs.
The Rebate Aggregator Checklist, an update from our 2018 report titled Drug Rebate Aggregators: Role in Drug Pricing, is intended to provide an overview of information that may be relevant to your evaluation process. It is not intended to provide legal or financial advice.
Below is a sample of the sections and content found in the Rebate Aggregator Checklist:
Payment terms
In this section we offer suggestions for reviewing rebate payment terms and the underpinnings of the rebate guarantee construct, including the following topics:
- How are rebates calculated?
- What fees are charged for these services?
- What are the important timing milestones between submission and receipt of payments?
- What is the basis of the rebate guarantee?
- How are network pharmacies defined?
- How are specialty drugs defined?
- Are there timing limitations for historical adjustments?
Formulary management terms
In this section we provide insights for reviewing formulary management requirements proposed by the aggregator, including the following points of interest:
- How are formularies categorized by aggregator?
- Are there any benefit types that are not eligible for rebates?
- Are copay accumulator and maximizer programs rebate eligible?
- Copay differential requirements?
- Bundling adoption requirements?
- Baseline market share performance requirements?
- Medical pharmacy formularies?
Aggregator Rebate contracts
In this section, outlined are tips for reviewing aggregator contract terms, contracting transparency, and other details for evaluation:
- Will this be an exclusive rebate aggregator agreement?
- Will aggregator allow client to manage their own manufacturer agreements?
- How many manufacturer agreements, and products are managed by aggregator?
- What is the timing of client notifications regarding changes in terms to existing rebate agreements, new agreements, and changes resulting from loss of patent exclusivity?
- What level of detail will aggregator share regarding contract terms?
- Will aggregator provide detailed reporting of the source of rebate revenues?
- Will aggregator provide a rebate eligible product list for each line of rebate contracting and formulary type?
Other Rebate Aggregator Checklist sections included in this report:
- Reporting
- Aggregator claim scrubbing rules
- Claims submission requirements
- Manufacturer audit support
- Managed Medicaid rebates
- Medicare Part B and D rebates
- Other Considerations
The report’s Table of Contents includes:
Drug Rebate Aggregator Background – pgs. 4-8
Drug Rebate Aggregator – Purchaser Checklist – pgs. 9-17
Drug Rebate Aggregator Service Providers – pgs. 18-42
- CVS Caremark
- Express Scripts
- MINCA, Inc./MedImpact
- OptumRx
- Prime Therapeutics
- Abarca Health
- DST Pharmacy Solutions
- Gateway Health Partners
- PBIRx
- RemedyOne
- RxPreferred Benefits
- WellDyneRx
IT/Service Vendors – pgs. 43-60
- Artia Solutions
- BeneCard PBF
- Change Healthcare
- CNSI
- Conduent
- eMax Health Systems
- Quantuvis
- The Rodenhizer Group
- TransactRx
References – pg. 61