On January 25, 2019, AMCP provided comments to CMS in response to the proposed rule on Modernizing Part D and Medicare Advantage to Lower Drug Prices and Reduce Out-of-Pocket Expenses. AMCP offered comments on the following CMS proposals; Providing Plan Flexibility to Manage Protected Classes; Prohibition Against Gag Clauses in Pharmacy Contracts; E-Prescribing and the Part D Prescription Drug Program; Updating Part D E-Prescribing Standards; Part D Explanation of Benefits; and Medicare Advantage and Step Therapy for Part B Drugs.
On December 31, 2018, AMCP provided comments to CMS on its Advanced Notice of Public Rulemaking (ANPRM) for a potential International Pricing Index (IPI) Model for Medicare Part B Drugs. The potential model would be phased in over a five-year period starting in Spring 2020 and will be tested as a pilot program through CMMI. It also seeks to reform the current “buy and bill” system for Part B drugs and alter reimbursement methodology. AMCP shared its concerns that elements outlined in the ANPRM need further consideration to ensure that they are sustainable solutions for decreasing medication costs before making substantial changes to existing programs.
On November 26, 2018, CMS issued a new proposed rule outlining potential policies that are intended to lower the cost of prescription drugs. Major Provisions in the proposed rule include; Providing Part D Prescription Drug Plan (PDP) flexibility to negotiate discounts for drugs in protected classes; Utilizing Real Time Benefits Tools (RTBT) in the Part D Program to increase drug price transparency at the point of prescribing; Codifying a policy to allow step therapy in Medicare Advantage for Part B Drugs; Amending regulations related to the Part D Explanation of Benefits (EOB) that plans send to beneficiaries to include drug pricing information and lower cost alternatives; Implementing a statutory provision prohibiting the use of gag clauses in pharmacy contracts; Considering a policy that would re-define negotiated price as the baseline, or lowest possible, payment to a pharmacy in future plan years as early as 2020.
AMCP webinar that reviewed the major provisions contained in a recently released advanced notice of proposed rulemaking from CMS on the International Drug Pricing Index for Part B drugs and a recently proposed rule on the Medicare Advantage and Part D Program.