Volleyed and thundered.
Everyone wants a formulary these days. Louisiana, Nebraska, North Carolina, and South Carolina are the latest to make at least public mention of exploring a drug formulary for their respective states' workers' compensation systems. They join California, Montana, Maine, Tennessee, and Arkansas, all of which are also thinking about formularies. And this movement, of course, builds on varying degrees of success observed in those states that already have formularies: Texas, Washington, Oklahoma, and Ohio.
Tennyson's Charge of the Light Brigade, to which I allude above, is a celebration of a very brave group of six hundred cavalry soldiers who fought in the Crimean War in the mid-19th century. The British soldiers depicted in the poem didn't quite realize what they were getting themselves into. Neither do some state regulators who are contemplating formulary implementation.
Formularies are an absolutely essential tool to mitigate prescription drug misuse and abuse within any workers' compensation system. But they're not easy to implement and some of the states contemplating it have not done the work necessary to implement such a measure. As I've stated time and time again, both here on this blog and in presentations and panels around the country, Texas passed HB 7 in 2005 - and finally got a formulary implemented in 2011 (and didn't get it fully implemented until 2013). What took so long? The hard work of creating, implementing, adopting and communicating critical prerequisites like pre-authorization processes, dispute resolution processes, medical treatment guidelines, and stakeholder acceptance.
I recall presenting on the topic of formularies at the South Carolina Work Comp Education Conference back in February of 2013. I talked about the concept generally and shared some of the early data coming out of Texas. My enthusiasm for formularies must have been obvious... because the backlash was swift. Several doctors in the room vowed they would cease taking work comp patients if such an approach was ever attempted in South Carolina. Several adjusters commented that it sounded great, but they couldn't imagine how it would work in their state. Defense attorneys told me they thought it was great... in theory. And the applicant attorneys just chuckled.
The desire to exercise better control of prescription drugs in work comp doesn't start with a formulary. A formulary is the fruition of appropriate regulatory groundwork.
My fear is that one or two bad formulary implementations at the state level will set the national movement toward formularies back several years. We can't afford any setbacks in the fight against prescription drug misuse and abuse. Better to do it right than to rush into something that a state lacks the infrastructure and experience to accomplish.
One step at a time.
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