Pharmaceutical Research & Manufacturers of America v. Nicholas

353 F. Supp. 2d 231, 2005 U.S. Dist. LEXIS 1217
CourtDistrict Court, D. Rhode Island
DecidedJanuary 27, 2005
Docket00-157-B-H, 04-161-S
StatusPublished

This text of 353 F. Supp. 2d 231 (Pharmaceutical Research & Manufacturers of America v. Nicholas) is published on Counsel Stack Legal Research, covering District Court, D. Rhode Island primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Pharmaceutical Research & Manufacturers of America v. Nicholas, 353 F. Supp. 2d 231, 2005 U.S. Dist. LEXIS 1217 (D.R.I. 2005).

Opinion

DECISION AND ORDER

SMITH, District Judge. *

I. Introduction

This case involves an effort by the State of Maine to. leverage its market power as a major purchaser of pharmaceuticals (in its role as administrator of the Medicaid program in Maine), to force the suppliers of these drugs to lower their prices for non-Medicaid eligible (but nevertheless quite poor) citizens of Maine.

This case has a considerable history. In 2000, the State of Maine (“the State” or “Maine”) developed a plan to address the difficult problem created by the spiraling costs of prescription drugs, and the burden placed upon its poor citizens as a result of these high costs. 1 Passage of Maine Rx precipitated this litigation, which began before Judge D. Brock Hornby in the District Court of Maine. After Judge Hornby issued an injunction preventing implementation of Maine Rx, the, case worked its way up to the United States Supreme Court. Ultimately the Supreme Court, affirming the First Circuit, reversed the injunction and remanded the case to the District Court for further proceedings. The case has been transferred to this writer as a result of the recusal of Judge Hornby and the other judges in the District of Maine.

In its review of the case, the Supreme Court issued five widely divergent opinions. Subsequent to the Court’s ruling, the State substantially revised Maine Rx. Thus, the plan .this Court now has before it for review on the present motions is not the same plan that the Supreme Court so painstakingly examined. As a result of the changes to Maine Rx, the State now contends in its Motion to Dismiss that the case is no longer ripe for review. The Plaintiff — Pharmaceutical Research and Manufacturers of America (“PhRMA”), a trade association representing manufacturers that account for more than seventy-five percent of brand name drug sales in the United States — in contrast, takes its cue from the concurring opinion of Justice Breyer and moves this Court to send the question whether Maine Rx Plus is consistent with the requirements of the Medicaid statute to the Secretary of the U.S. Department of Health and Human Services (“the Secretary” or “HHS”). While the history of the case is long and tortured the motions before this Court can be disposed of in straight-forward fashion: The question at the heart of the matter is whether PhRMA’s claim that the Maine Rx Plus Program is preempted by federal law is ripe for review at this time. This question must be examined through the prism of both the statutory and regulatory frame *233 work of the Medicaid Act, as well as the opinions of the Supreme Court Justices. In the end, it is quite clear that PhRMA’s claim is not ripe for review and must be dismissed.

II. Background

A. Medicaid Generally

“In response to increasing Medicaid expenditures for prescription drugs, Congress enacted a cost-saving measure in 1990 that requires drug companies to pay rebates to States on their Medicaid purchases.” Pharm. Research & Mfrs. of Am. v. Walsh, 538 U.S. 644, 649, 123 S.Ct. 1855, 155 L.Ed.2d 889 (2003) (internal footnote omitted). “Over the last several years, state legislatures have enacted supplemental rebate programs to achieve additional cost savings on Medicaid purchases as well as for purchases made by other needy citizens.” Id. In negotiating rebates with the pharmaceutical companies, one of the negotiating tools statutorily available to state government is the use of a “prior authorization” scheme. 2 When a particular drug is subject to prior authorization, before a doctor can prescribe that drug to a Medicaid recipient and be assured the recipient will receive the Medicaid discount, the doctor must receive prior authorization from the appropriate government representative. Because this imposes an additional hurdle that stands between the pharmaceutical company and its potential customer, and given that there are usually alternative drugs available that doctors may prescribe that are not subject to a prior authorization scheme, pharmaceutical companies are anxious to avoid having their drugs' subjected to such prior authorization schemes. 3

*234 B. The Original Maine Plan (“Maine Rx”)

The right to negotiate rebates, in conjunction with prior authorization schemes, provides states with an effective tool to leverage their purchasing power in the pharmaceutical market. During the summer of 2000, Maine enacted its Maine Rx prescription drug plan, seeking to do exactly that in an effort to obtain less expensive prescription drugs for a greater number of its citizens. 2000 Me. Legis. Serv. 786 (S.P.1026) (L.D.2599); see Timothy Stoltzfus Jost, Pharmaceutical Research and Manufacturers of America v. Walsh. The Supreme Court Allows the States to Proceed with Expanding Access to Drugs, 4 Yale J. Health Pol’y, L. & Ethics 69, 77 (2004) (“Maine’s program, at issue in Walsh, attempted to use this lever — the threat of requiring prior authorization — to make discounts available to all residents of the state who lacked insurance coverage for drugs, regardless of income.”). The Maine Rx Program had three primary provisions: (1) it prohibited profiteering and excessive pricing by drug manufacturers and created extensive civil penalties for violations; (2) it prohibited manufacturers from altering their distribution schemes so as to avoid the application of the Maine law; and (3) it ordered the Maine Commissioner of Human Services to negotiate with the drug manufacturers to provide a rebate which would apply every time an uninsured Maine citizen bought a prescription at a pharmacy in Maine. In order to persuade manufacturers to cooperate in the rebate program, the State created two penalties for failure to negotiate rebates: first, the names of those manufacturers that did not participate were to be made public; and second, the drugs of the nonparticipating manufacturers would be put on a list of drugs requiring prior authorization before they could be approved for Medicaid reimbursement.

PhRMA challenged the Maine Rx Program on two grounds: that it violated the Commerce Clause and was preempted by the federal Medicaid statute. PhRMA sought an injunction against the implementation of Maine Rx. Judge Hornby, after a hearing, concluded that the anti-profiteering provision and the rebate provision violated the Commerce Clause; further, because Maine could identify no Medicaid-related purpose in the prior authorization requirement, Maine Rx was preempted under the Supremacy Clause. The Court thus granted a preliminary injunction to PhRMA, ordering Maine not to “penaliz[e] manufacturers, by placing their drugs on prior listing status, for refusing to negotiate or to pay a rebate to Maine’s Rx program,” and prohibiting Maine “from seeking to enforce the illegal profiteering portion of the statute against transactions that occur outside the State of Maine.” Pharm. Research & Mfrs. of Am.

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353 F. Supp. 2d 231, 2005 U.S. Dist. LEXIS 1217, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pharmaceutical-research-manufacturers-of-america-v-nicholas-rid-2005.