See what Patient Groups and Consumer Groups said about the Express Scripts-Medco Merger
Patient Groups:
Hemophilia Federation of America - Link to PDF
"We are writing in regard to the impact of consolidation in the health care delivery marketplace, and most recently the proposed merger between Express Scripts and Medco. As you evaluate this merger and its impact on consumers, we encourage you to examine the needs of the patients who will be affected, especially those with rare and chronic diseases."
"Health outcomes associated with the delivery of healthcare for individuals with bleeding disorders are critically dependent on highly qualified and specialized pharmacies for the dispensing of their treatment."
"Treatment for a bleeding disorder is typically known as factor replacement therapy (Factor), and must be transfused intravenously at home by the patient, a family member or infusion therapy specialist. It is extremely important that patients have a choice when selecting a specialty pharmacy health care provider to ensure their provider has experience in dispensing these therapies; clinically relevant customer service to respond to questions and concerns; and any adverse events a patient may experience."
National Hemophilia Foundation - Link to PDF
"We urge the Committee to look closely at the implications of the merger on consumer choice and access to prescription drugs in the specialty pharmacy market."
"Due to the high cost of hemophilia care most insurers utilize specialty pharmacy services. The proposed merger would combine two of the largest specialty pharmacies – Express Scripts’ CuraScript Pharmacy and Medco’s Accredo. The Foundation wants to assure: that patients have continued access to the very specialized care that is critical to their health and well-being; that choice of treatments are determined by the prescribing physician in consultation with the patient; and that cost-sharing is affordable. The Committee should evaluate the potential impact of a merger as related to these issues"
National Gaucher Foundation - Link to PDF
"The National Gaucher Foundation (NGF) writes you today to express our concerns with the proposed merger of Express Scripts, Inc. and Medco Health Solutions. We are very supportive of the Commission's decision to review the proposed merger and we ask that the Commission carefully examine the implications of the merger on access to prescription drugs in the specialty pharmacy market."
"The new combined firm will have increased incentive and ability to restrict patient access to the specialty pharmacy care that many patients of Gaucher Disease depend on."
"We are concerned the merger will increase the ability of the joint firm to enter into exclusive distribution agreements with pharmacy manufacturers, which have previously raised the cost of drugs and further restricted consumer access to life-saving drugs."
"It is of utmost importance, therefore, that these patients maintain the ability to receive these treatments at a qualified infusion center of their choosing. NGF asks the Commission, therefore, to critically examine the proposed deal's impact on patient choice for treatment options."
Louisiana Lupus Foundation - Link to PDF
"We from the Louisiana Lupus Foundation are writing today to express our concerns with the proposed Express Scripts, Inc./Medco Health Solutions merger. We are especially concerned about what this merger may mean for patient choice and access to specialty pharmaceuticals, and we ask that the Commission carefully examine the impact of the merger in the specialty pharmacy market."
"We are concerned that the merger may harm lupus patients by denying them choices in pharmacy and diminishing their access to critical medications. The extreme dominance of Express-Scripts-Medco in the PBM and specialty pharmacy markets will likely increase the incentive and ability for the company to restrict network access and engage in exclusive distribution arrangments that drive patients away from their pharmacy of choice and into their captive mail-order services."
"Such restrictions deny patients choice, negatively impact patient adherence, lead to disruptions in the continuity of care, and significantly limit access for certain patients, especially those living in rural areas."
Consumer Groups:
Major Consumer Groups:
NLARx, Consumers Union, CFA, NCL & U.S. PIRG - Link to PDF
"We write you today to express our opposition to Express Scripts' proposed acquisition of Medco Health Solutions."
"This incredible consolidation of the specialty market is of particular concern given the rapidly increasing cost of specialty pharmaceuticals."
"We are concerned that by granting Express Scripts such incredible dominance of the specialty pharmacy market, the merger would decrease access to these critical treatments by restricting patient choice in pharmacies and increasing the potential for price gauging."
"Enhancing Express Scripts -Medco specialty pharmacy operations will only increase the incentive for the company to drive patients in-house and away from the patient's specialty provider of choice."
"It is important to point out that the specialty pharmacy market is a relatively new and still developing area, and no single business model has proven to be most efficient. The innovation necessary to help this market evolve in the most cost-efficient manner would be greatly crippled by the merger."
American Antitrust Institute - Link to PDF
"One effect of a greatly enlarged Express Scripts-Medco PBM would be expanded control of patient data. The merged company would likely have the incentive and ability to use this data to move patients to its own specialty and mail order pharmacy operations. This concern is real in light of CVS Caremark's demonstrated ability to use data received in its PBM capacity to boost sales of its CVS pharmacies."
"Each of the three major PBMs has acquired specialty pharmaceutical companies in recent years, reducing the number of independent specialty pharmacies and giving the major PBMs power over the downstream specialty pharmacy distribution chain. Some critics have suggested that it is a common business practice for these PBMs to prevent other pharmacies from dispensing specialty drugs and to force patients to use the PBM's mail order facility, thereby foreclosing competition from rival pharmacies. If true, these restricted networks disrupt the continuity of care and degrade health outcomes by forcing patients to switch away from their pharmacy of choice."
"In the past, Express Scripts has imposed substantial price increases after becoming the sole distributor of certain drugs. This suggests that these acquisitions and distribution alliances have led to increased prices as well as decreased service and consumer choice in providers of several specialty drugs."
"Because of the large PBMs' vertical integration and enhanced buyer power, the merger will also likely cause anticompetitive harm in the specialty pharmacy and mail order pharmacy market segments."
Patient Groups:
Hemophilia Federation of America - Link to PDF
"We are writing in regard to the impact of consolidation in the health care delivery marketplace, and most recently the proposed merger between Express Scripts and Medco. As you evaluate this merger and its impact on consumers, we encourage you to examine the needs of the patients who will be affected, especially those with rare and chronic diseases."
"Health outcomes associated with the delivery of healthcare for individuals with bleeding disorders are critically dependent on highly qualified and specialized pharmacies for the dispensing of their treatment."
"Treatment for a bleeding disorder is typically known as factor replacement therapy (Factor), and must be transfused intravenously at home by the patient, a family member or infusion therapy specialist. It is extremely important that patients have a choice when selecting a specialty pharmacy health care provider to ensure their provider has experience in dispensing these therapies; clinically relevant customer service to respond to questions and concerns; and any adverse events a patient may experience."
National Hemophilia Foundation - Link to PDF
"We urge the Committee to look closely at the implications of the merger on consumer choice and access to prescription drugs in the specialty pharmacy market."
"Due to the high cost of hemophilia care most insurers utilize specialty pharmacy services. The proposed merger would combine two of the largest specialty pharmacies – Express Scripts’ CuraScript Pharmacy and Medco’s Accredo. The Foundation wants to assure: that patients have continued access to the very specialized care that is critical to their health and well-being; that choice of treatments are determined by the prescribing physician in consultation with the patient; and that cost-sharing is affordable. The Committee should evaluate the potential impact of a merger as related to these issues"
National Gaucher Foundation - Link to PDF
"The National Gaucher Foundation (NGF) writes you today to express our concerns with the proposed merger of Express Scripts, Inc. and Medco Health Solutions. We are very supportive of the Commission's decision to review the proposed merger and we ask that the Commission carefully examine the implications of the merger on access to prescription drugs in the specialty pharmacy market."
"The new combined firm will have increased incentive and ability to restrict patient access to the specialty pharmacy care that many patients of Gaucher Disease depend on."
"We are concerned the merger will increase the ability of the joint firm to enter into exclusive distribution agreements with pharmacy manufacturers, which have previously raised the cost of drugs and further restricted consumer access to life-saving drugs."
"It is of utmost importance, therefore, that these patients maintain the ability to receive these treatments at a qualified infusion center of their choosing. NGF asks the Commission, therefore, to critically examine the proposed deal's impact on patient choice for treatment options."
Louisiana Lupus Foundation - Link to PDF
"We from the Louisiana Lupus Foundation are writing today to express our concerns with the proposed Express Scripts, Inc./Medco Health Solutions merger. We are especially concerned about what this merger may mean for patient choice and access to specialty pharmaceuticals, and we ask that the Commission carefully examine the impact of the merger in the specialty pharmacy market."
"We are concerned that the merger may harm lupus patients by denying them choices in pharmacy and diminishing their access to critical medications. The extreme dominance of Express-Scripts-Medco in the PBM and specialty pharmacy markets will likely increase the incentive and ability for the company to restrict network access and engage in exclusive distribution arrangments that drive patients away from their pharmacy of choice and into their captive mail-order services."
"Such restrictions deny patients choice, negatively impact patient adherence, lead to disruptions in the continuity of care, and significantly limit access for certain patients, especially those living in rural areas."
Consumer Groups:
Major Consumer Groups:
NLARx, Consumers Union, CFA, NCL & U.S. PIRG - Link to PDF
"We write you today to express our opposition to Express Scripts' proposed acquisition of Medco Health Solutions."
"This incredible consolidation of the specialty market is of particular concern given the rapidly increasing cost of specialty pharmaceuticals."
"We are concerned that by granting Express Scripts such incredible dominance of the specialty pharmacy market, the merger would decrease access to these critical treatments by restricting patient choice in pharmacies and increasing the potential for price gauging."
"Enhancing Express Scripts -Medco specialty pharmacy operations will only increase the incentive for the company to drive patients in-house and away from the patient's specialty provider of choice."
"It is important to point out that the specialty pharmacy market is a relatively new and still developing area, and no single business model has proven to be most efficient. The innovation necessary to help this market evolve in the most cost-efficient manner would be greatly crippled by the merger."
American Antitrust Institute - Link to PDF
"One effect of a greatly enlarged Express Scripts-Medco PBM would be expanded control of patient data. The merged company would likely have the incentive and ability to use this data to move patients to its own specialty and mail order pharmacy operations. This concern is real in light of CVS Caremark's demonstrated ability to use data received in its PBM capacity to boost sales of its CVS pharmacies."
"Each of the three major PBMs has acquired specialty pharmaceutical companies in recent years, reducing the number of independent specialty pharmacies and giving the major PBMs power over the downstream specialty pharmacy distribution chain. Some critics have suggested that it is a common business practice for these PBMs to prevent other pharmacies from dispensing specialty drugs and to force patients to use the PBM's mail order facility, thereby foreclosing competition from rival pharmacies. If true, these restricted networks disrupt the continuity of care and degrade health outcomes by forcing patients to switch away from their pharmacy of choice."
"In the past, Express Scripts has imposed substantial price increases after becoming the sole distributor of certain drugs. This suggests that these acquisitions and distribution alliances have led to increased prices as well as decreased service and consumer choice in providers of several specialty drugs."
"Because of the large PBMs' vertical integration and enhanced buyer power, the merger will also likely cause anticompetitive harm in the specialty pharmacy and mail order pharmacy market segments."