Drug Pricing Expert
A drug pricing expert witness understands pricing trends and drug classification systems and how these impact the overall cost of health care. Our team has over 35 years of executive experience in drug pricing expertise pharmaceutical supply chain management management and pharmaceutical pricing. To understand drug pricing in the product supply chain and bundling and purchasing conventions for pharmaceutical products and other medical supplies, it is important to understand drug and pharmaceutical classification systems. Drug pricing experts should know that payor drug pricing models are often managed by pharmacy benefits management (PBM)s. Most importantly, in drug pricing expert testimony in litigation where collateral source rules apply, our team specializes in proving the Usual Customary and Reasonable (UCR) rates for drug charges. Note: Featured image credit: Academy of Managed Care Pharmacy
Standardized biomedical information provide benefits in conducting research. However, practical use of this information often requires mapping across terminological systems—a complex and time-consuming process. According to National Library of Medicine papers, there are at least 12 standards nd drug databases of import. Nonetheless, a practical approach must be taken when providing opinions regarding the Usual Customary and Reasonable Charge data for drug pricing. Here is a very brief look at three major Classification Systems an drug pricing expert should know: NDC, GPI, and RxNorm
National Drug Code (NDC)
The Drug Listing Act of 1972 requires registered drug establishments to provide the Food and Drug Administration (FDA) with a current list of all drugs manufactured, prepared, propagated, compounded, or processed by it for commercial distribution. (See Section 510 of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. § 360)). Drug products are identified and reported using a unique, three-segment number, called the National Drug Code (NDC), which serves as a universal product identifier. According to the FDA, “Section 510(p) of the FD&C Act (21 USC 360(p)) now requires registration and listing information for human drugs to be submitted electronically.” NDC can be displayed in 10 digits but proper billing requires that 11 digits of the NDC be used. Drug pricing expert analysis is better served with full 11 digit NDC information.
Generic Product Identifier (GPI)
To better understand drug pricing, one should also understand GPI. The Medi-Span Wolters Kluwer GPI (Generic Product Identifier) denotes pharmaceutically equivalent drug products. Products having the same 14-character GPI are identical with respect to active ingredient(s), dosage form, route, and strength or concentration. The GPI does not consider the presence of inactive ingredients. Importantly, health plans (payors) and pharmacy benefit management systems (PBMs) use GPI for formularies. All of these factors should be comprehended in proper drug pricing expert analysis. For example, category 57 of the GPI, Central Nervous System Agents has 98 entries from ALPRAZolam to Xanax XR.
Drug pricing expert analysis may be strengthened by having a perspective of prescriber volume. RxNorm is the data standard when prescribing via an electronic health record system. According to the U.S. National Library of Medicine, “RxNorm is two things: a normalized naming system for generic and branded drugs; and a tool for supporting semantic interoperation between drug terminologies and pharmacy knowledge base systems. The National Library of Medicine (NLM) produces RxNorm. Hospitals, pharmacies, and other organizations use computer systems to record and process drug information. Because these systems use many different sets of drug names, it can be difficult for one system to communicate with another. To address this challenge, RxNorm provides normalized names and unique identifiers for medicines and drugs. The goal of RxNorm is to allow computer systems to communicate drug-related information efficiently and unambiguously. RxNorm contains the names of prescription and many over-the-counter drugs available in the United States. RxNorm includes generic and branded:
- Clinical drugs – pharmaceutical products given to (or taken by) a patient with therapeutic or diagnostic intent
- Drug packs – packs that contain multiple drugs, or drugs designed to be administered in a specified sequence”
Adoption of RxNorm grows significantly with the advent of the ARRA HITECH Act which provided stimulus funds for Meaningful Use of Electronic Health Records (E.H.R.s). EHRs use Computerized Provider Order Entry (CPOE) and electronic prescribing (ePrescribing) to electronically notify a pharmacy of a physician’s order to fulfill a prescription drug to a patient.
In addition to the standards noted, drug information for drug pricing expert analysis may include:
Associated Diagnosis and Procedure Codes (ICD-10-CM/PCS, HCPCS, CPT)
Package pricing, average wholesale pricing (AWP), etc.
Format (pill, liquid, gas, etc.)
Package types & descriptions
Route of Administration
Controlled Substance (DEA) Status
Maintenance drug status
Drug pricing terminology used by Pharmacy Benefit Management Systems or PBMs may include:
· Average Wholesale Price (AWP) and Average Sales Price (ASP)
· NDC price reporting
· Mark-Ups & Price Spreads
· “Brand” and “Generic”
· Clinical Rules & Protocols
· Plan Design
· Payor Account Crediting
Drugs Billed as Part of Inpatient vs. Outpatient Care
The cost of drugs may vary depending on whether the drug is prescribed and delivered in a hospital (or, a hospital or physician owned ambulatory surgery center) or to an insured who received the medication at a pharmacy.