Leveraging Acquisition Cost Based Pharmacy Pricing

Jack Towarnicky of aequum health joined Scott McKibbin in presenting Hidden Opportunities: A “Dope” Response to Pharmacy “Transparency.” This was a third webinar in Humaculture’s Strategic Compliance Series that addresses how to strategically leverage the No Surprises Act (NSA) and Transparency in Coverage to create a competitive advantage.

A recording of this webinar can be viewed here.

Health plan price transparency helps healthcare consumers know the true cost of a covered service before receiving care. The passage of the NSA now requires plans to offer participants health care price comparisons over the phone and online. Beginning July 1, 2022, most group health plan and issuers of group or individual health insurance will begin posting pricing information.

Pharmacy Transparency Key Takeaways

Participants in this webinar learned why the new pharmacy transparency law will not increase transparency, but will increase costs, administration and litigation risk.

  • Transparency is a misnomer; new rules don’t provide greater transparency regarding your plan’s drug utilization
  • Pharmacy pricing is likely to continue to be rather “opaque”

The new mandated disclosures will be incomplete and inapplicable to your plan, backward-looking and delayed. So, you may have access to limited, potentially misleading 2021 drug price data in time for 2024 renewals for participant coverage elections that take effect January 2025 likely increase costs, administration and litigation risk, especially once providers who currently charge at below median levels see they can charge more.

This session focused on leveraging Acquisition Cost Based Pharmacy Pricing and Behavioral Design and Messaging as strategic actions organizations can take to optimize compliance. Actual acquisition cost is the purchase price of a drug paid by a pharmacy net all discounts, rebates, chargebacks and other adjustments to the price of the drug.

Acquisition Cost Based Pharmacy Pricing and Behavioral Design and Messaging offer a strategic alternative that will:

  • Avoid what can be avoided
  • Provide true transparency with pharmacy benefits with participant paid cost sharing that reflects the true cost of the medication
  • Empower consumers to make better, more clinically appropriate decisions with information that identifies therapeutically equivalent medication alternatives
  • Communicate any negatives from changes in coverage as the result of compliance
  • Inform and educate consumers (before they become patients)

A Strategic Response to Compliance

Plan sponsors should take strategic action – changes that go far beyond simple compliance with the No Surprises Act and the Consolidated Appropriations Act – to ensure that their employer-sponsored, self-insured plans incorporate the most effective strategies available today for the “health and wealth” of their participants.

Based on all metrics and experience, these strategies include effectively designed acquisition cost-based pharmacy pricing, HSA-capable coverage, along with reference-based pricing, adequate participant protections against balance billing, participant advocacy and litigation support as needed. Features and transition provisions specifically address the needs of Americans with lower wages, as well as those living paycheck to paycheck.


Join Jack and others for the last two sessions in the five-part series. Next up is Hidden Opportunities: Mental Health Parity – A Lucid Approach, on Thursday, April 21, at 1 p.m. EST. The fifth and final session is scheduled for May 19, at 1 p.m. EST titled: Pest Management, Minimizing Plan Losses Through Fee Disclosure. Register here.