Governor’s Action on MAT Bills

January 2, 2020

On December 31, the Governor signed into law A2904 Quart, Same as S4808 Weprin that prohibits prior authorization for certain medications used in the treatment of substance use disorders in most commercial insurance policies.

On January 1, Governor Cuomo vetoed S05935A, Harckham, Same as A07246-B, Biaggi that  would have prohibited Prior Authorization (PA) for certain SUD medications (MAT) for New Yorkers enrolled in Medicaid.

The NYS Council is deeply disappointed with the Governor’s decision to veto the Medicaid bill.  It was clear from the outset the Administration was concerned that lifting PA requirements for certain SUD meds in Medicaid would be expensive.  But the human costs associated with delayed access to MAT are far greater.   The disparity that now exists as a result of these actions must be addressed. 

Regarding the Governor’s veto of the bill that would have lifted Prior Authorization of certain SUD medications in the Medicaid Program, we knew the Administration had been struggling to ensure all manufacturers of certain frequently prescribed MAT medications were willing to participate in New York’s Drug Rebate Program. According to the Veto Message (below) one pharmaceutical manufacturer refused to play ball.

At the end of the day we hope you will agree that decisions about which medications are prescribed to treat mental health or substance use disorders should ultimately be based on what is best for the individual requiring the medication.

Excerpted from Veto message:

“…However,  in  reality,  this  bill  would provide  a  statutorily-authorized  unfair  competitive advantage to one pharmaceutical manufacturer in particular. This  manufacturer  fails  to offer  sufficient  competitive  pricing  to be included on the preferred drug list or on many  managed  care  organization  formularies,  and  in lobbying  for this legislation to eliminate prior authorization requirements, requires Medicaid plans and the State to pay whatever price  this manufacturer charges. Indeed, its website touts its success in obtaining “legislative changes in some states to force publicly financed payers to reimburse  all  products.” There are no clinical differences or benefits among the available drugs in the opioid use disorder (OUD) class. Enactment of this law, therefore, does nothing to improve access,  rather  it only  increases  the  bottom line of one particular manufacturer costing the State approximately $30 million..”

“…Further, in the Executive Budget I will propose to create a single preferred-drug list  for  MAT  that will  be  available  for  all  Medicaid  recipients,  without allowing a manufacturer to name its price, requiring the State to pay…”

VETO MESSAGE – No. 292

TO THE SENATE:

I am returning herewith, without my approval, the following bill:

Senate Bill Number 5935-A, entitled:

“AN  ACT to amend the social services law and the public health law,

in relation to medication  for  the  treatment  of  substance  use

disorders”

NOT APPROVED

The  opioid epidemic is an insidious public health crisis that contin-

ues to ravage communities across  New  York.  I  have  taken  aggressive

action to combat this epidemic, and we are seeing results with the first

reduction  in  opioid overdose deaths in 10 years. However, there is far

more to be done, and expanding and ensuring meaningful access to medica-

tion assisted treatment is a critical step  to  eliminating  the  opioid

epidemic.

This  bill would ostensibly eliminate the need for prior authorization

from a Medicaid managed care plan when a patient needs to access medica-

tion assisted treatment (MAT). However,  in  reality,  this  bill  would

provide  a  statutorily-authorized  unfair  competitive advantage to one

pharmaceutical manufacturer in particular. This  manufacturer  fails  to

offer  sufficient  competitive  pricing  to be included on the preferred

drug list or on many  managed  care  organization  formularies,  and  in

lobbying  for this legislation to eliminate prior authorization require-

ments, requires Medicaid plans and the State to pay whatever price  this

manufacturer charges. Indeed, its website touts its success in obtaining

“legislative changes in some states to force publicly financed payers to

reimburse  all  products.” There are no clinical differences or benefits

among the available drugs in the opioid use disorder (OUD) class. Enact-

ment of this law, therefore, does nothing to improve access,  rather  it

only  increases  the  bottom line of one particular manufacturer costing

the State approximately $30 million.

The publicly available statements of the manufacturer are prima  facie

evidence  of  the  true  nature  of  this bill. Further, we have already

implemented many laws and policies to ensure patients have access to MAT

– there is no prior authorization for preferred or formulary versions of

buprenorphine  and  injectable  naltrexone.  Even  if  a  drug  is   not

preferred,  a  patient  is guaranteed a 5-day dosage when they present a

prescription while prior authorization takes place, which must be within

24 hours of receipt of the requested information. Because we are  facing

a structural deficit in Medicaid, the $30 million cost is untenable when

it comes at no clinical benefit to any New Yorker.

This  bill  also  prohibits  prior  authorization  for  naltrexone, an

injectable drug that is also a single brand name drug. Since current law

requires one MAT drug per class  be  on  the  preferred  drug  list  and

managed  care  plan formularies, naltrexone is already exempt from prior

authorization requirements. However, if additional drugs from this class

come to market, at that point, this provision provides price  protection

for that brand name drug.

This  bill  also  eliminates  any  prior  authorization for methadone.

Diversion is a  particular  concern  with  methadone,  which  can  cause

significant  harm  to the people the drugs are intended to help. This is

why methadone, when used to treat  OUD,  can  only  be  administered  or

dispensed  at an OASAS Article 32 clinic for which the State has already

removed any prior authorization requirements. Methadone’s use at such  a

facility does not result in diversion, eliminating safety concerns.

We  offered many potential compromises to the legislature on this bill

to make sure access could be guaranteed while not resulting in  a  give-

away  to  manufacturers,  and  to  ensure that there were not unintended

consequences. Every effort at a compromise was rejected.

Thanks to many initiatives spearheaded by my administration  more  New

Yorkers  than ever have access to MAT for OUD. This year we aggressively

expanded access to MAT both by increasing the number of medical  profes-

sionals  who  are designated to prescribe and by expanding the number of

settings in which MAT can be prescribed. Further, in the Executive Budg-

et I will propose to create a single preferred-drug list  for  MAT  that

will  be  available  for  all  Medicaid  recipients,  without allowing a

manufacturer to name its price, requiring the State to pay.

For the foregoing reasons, I cannot support this legislation as  writ-

ten. This  bill  is  a giveaway to manufacturers, risks the important

progress we have made to combat opioid use disorder, and does  not  have

any clinically beneficial impact for New Yorkers.

The bill is disapproved.                    (signed) ANDREW M. CUOMO