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National Association of Chain Drug Stores commented this week on the proposed regulations on the use of managed care in Medicaid and in the Children’s Health Insurance Program… create standards that will serve to maintain the strong link between Medicaid patients and community pharmacies and the valuable services that these pharmacies provide… six key areas:

1. Outpatient Drugs…preventing mandatory use of mail-order pharmacies,…preventing a reliance on closed networks for…specialty medications
2. Network Adequacy and Availability of Services – advancing the belief that "patients should be allowed the freedom to select a pharmacy that best fits their personal health needs
3. Program Integrity and Auditing – recognizing the "balance between the need to ensure integrity in the Medicaid program and the need to afford due process and equal protection to providers"
4. Medical Loss Ratio – allowing medication therapy management services to be considered as a healthcare activity, rather than an administrative cost
5. Provider Payment Initiatives – incorporating innovative pharmacy services as part of managed care organizations’ strategies for delivering healthcare services
6. Development of a Medicaid Managed Care Quality Rating System – including appropriate medication-use metrics