Statement of the National Association of Chain Drug Stores For the anti-viral medications

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					               Statement of the National Association of Chain Drug Stores

                                  For the Joint Hearing on

    “H1N1 Preparedness: An Overview Of Vaccine Production And Distribution"

                    House Energy and Commerce Committee
     Subcommittee on Health and Subcommittee on Oversight and Investigations
                               November 18, 2009

Chairmen Pallone and Stupak, the National Association of Chain Drug Stores appreciates
the opportunity to submit this statement for today’s hearing. Addressing the serious public
health threat posed by the H1N1 virus should be a top concern to our nation’s political
leaders and its health providers, so we commend you for holding this important hearing to
raise public awareness about the problem and to explore ways to address production and
distribution issues. NACDS, its member companies and the 120,000 dedicated pharmacists
who work in chain community pharmacies stand ready to assist policymakers and public
health officials at all levels of government in preventing the spread, and alleviating the
symptoms, of this dangerous disease.

The National Association of Chain Drug Stores (NACDS) represents 154 traditional drug
stores, supermarkets, and mass merchants with pharmacies – from regional chains with four
stores to national companies. NACDS members also include more than 900 pharmacy and
front-end suppliers, and over 70 international members from 24 countries. Chains operate
37,000 pharmacies, and employ more than 2.5 million employees, including 118,000 full-
time pharmacists. They fill more than 2.5 billion prescriptions annually, which is more than
72 percent of annual prescriptions in the United States. The total economic impact of all
retail stores with pharmacies transcends their $815 billion in annual sales. Every $1 spent in
these stores creates a ripple effect of $3.82 in other industries, for a total economic impact of
$3.11 trillion, equal to 26 percent of GDP.

The first wave of the H1N1 pandemic began in the spring of this year, originating in Mexico
and spreading quickly into the United States and other countries, forcing public health
officials to dramatically revise their pandemic plans. Although the severity of the illness
was mild -- comparable to seasonal flu -- it was possible that subsequent waves of the
pandemic would be more virulent beginning in the fall. Another grave concern was the fact
that H1N1 influenza seemed to occur more frequently and with greater morbidity in children
and young adults than seasonal influenza.
The resulting mass H1N1 vaccination campaign is the largest such undertaking in history,
requiring broad coordination across the entire healthcare continuum and an increase in the
number of vaccination providers. Community pharmacies are uniquely capable of
immunizing large numbers of people, thanks to their convenient locations, easy access
during evenings and weekends and specially trained pharmacists. The laws in all fifty states
authorize pharmacists to administer vaccinations. There are more than 56,000 community
pharmacies in every community in the country, with nearly 80,000 pharmacists qualified to
administer vaccinations. During the current influenza season, pharmacists are expected to
administer more than 5 million seasonal influenza vaccinations. Pharmacies also provide
oral anti-viral medications and ancillary health care supplies, such as hand sanitizers, as well
as retail health clinics offering additional healthcare services in many locations. Pharmacies
are also technologically proficient, using real-time electronic claims processing systems to
access patient eligibility, coverage limitations, and copayments for pharmacy benefits.

During the summer, chain pharmacies began making plans to support public health H1N1
pandemic initiatives, specifically for administration of H1N1 vaccine and distribution of oral
anti-viral agents. Due to the large number of unknown variables in state and federal
planning, collaboration with other provider groups, public health agencies, and government
officials was necessary to promote consistency and operational effectiveness. To address
these issues, NACDS convened a stakeholder workgroup meeting with pharmacy
representatives and other key organizations1, and after several meetings, produced the
Operational Framework for Partnering with Pharmacies for Administration of 2009 H1N1
Vaccine, a document published by the Association of State and Territorial Health Officials
(ASTHO) to serve as a guide to state and territorial health officials. This Framework
describes the unique capabilities of community pharmacies to administer H1N1 vaccine, a
template provider agreement between public health and community pharmacies, and a
template executive order proposing emergency amendments to expand state-level use of
community pharmacists in H1N1 vaccination programs. In addition, NACDS continued to
work with the American Pharmacists Association and America’s Health Insurance Plans
(AHIP) to develop a mechanism for pharmacies to submit medical claims to health plans for
reimbursement of H1N1 vaccine administration, culminating in a recommended roster
billing form that can be used if this service is not covered through the health plan’s
pharmacy benefit.

We are pleased to report that the potential contribution of community pharmacies has been
well recognized in public health pandemic plans. Community pharmacies have enrolled
broadly as H1N1 vaccine providers in state provider networks. Several states have issued
Emergency Orders to expand the ability of pharmacists to administer H1N1 vaccine, such as
by lowering the age limits and streamlining H1N1 vaccination protocols. Many state
Medicaid programs issued rules to reimburse pharmacies for administering H1N1 vaccine to

         The American Pharmacists Association, the National Alliance of State Pharmacy Associations, the
National Community Pharmacists Association, the Food Marketing Institute, the Convenient Care Association,
the Healthcare Distribution Management Association, Rx Response, the Association of State and Territorial
Health Officials, the National Association of County and City Health Officials, the Centers for Disease Control
and Prevention, the Department of Homeland Security, the Department of Health and Human Services, and the
Federal Emergency Management Agency.
beneficiaries. Community pharmacies prepared their pharmacists and contract vendors to
receive and administer H1N1 vaccine, and now await delivery of the vaccine for
administration to priority patient groups. In addition to community pharmacy’s engagement
in H1N1 prevention, it also is engaged in treatment. In response to the ongoing shortage of
commercially manufactured Tamiflu for Oral Suspension, an important anti-viral medication
for high-priority pediatric patients, pharmacists continue to compound the liquid product in
cooperation with guidance from the Food and Drug Administration and the Centers for
Disease Control and Prevention.

Community pharmacy’s support of H1N1 vaccination involves ongoing challenges. The
wide variety of state and local H1N1 vaccination processes and restrictions have added
complexity to community pharmacy support and we would recommend a more uniform
process in the future. The uncertainty of product delivery, including the lack in advance
identification of which product type and quantities will be delivered, and the undefined
delivery schedule make it difficult to schedule vaccination services. There has been an
unwillingness of some state officials to ship vaccine to non-resident locations, failing to take
advantage of the efficiency of chain pharmacy distribution centers. There continues to be
lack of clarity concerning some health plan’s coverage, billing procedures, and patient
copayments for H1N1 vaccinations.

In conclusion, we appreciate federal and state efforts to provide vaccine to protect the public
from H1N1 influenza, and their recognition of the contributions of community pharmacies.
The experience from this relatively mild pandemic and the difficulties implementing a
nationwide solution should improve future efforts. Community pharmacies, the face of
neighborhood health care, remain committed to assist public health efforts to protect our
citizens through convenient vaccination services and distribution of influenza
countermeasures. We look forward to working with your committees and Congress as a
whole to ensure that the nation’s community pharmacies are utilized to the greatest extent
possible in helping combat this serious health threat. Thank you for the opportunity to
submit this statement. If you have any questions, please contact Paul T. Kelly, Vice
President, Federal Government Affairs.

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Description: Statement of the National Association of Chain Drug Stores For the anti-viral medications