Cell & Gene Therapies (CGT) offer potentially curative treatment to patients with chronic and hereditary conditions but carry high price tags. One proposal to overcome such financing challenges is to create a national risk pool.
AMCP Comment Letter on Guarding U.S. Medicare Against Rising Drug Costs (GUARD) Model to HHS
The Academy of Managed Care Pharmacy (AMCP) appreciates CMS’s efforts to address rising drug costs through the proposed GUARD Model. While the model reflects an important policy objective, several aspects raise concerns for managed care pharmacy related to operational feasibility, pricing dynamics, and the extent to which anticipated savings will translate into meaningful benefits for plans and beneficiaries. The following comments highlight key areas where additional clarity and refinement are needed.
Related
The Academy of Managed Care Pharmacy (AMCP) thanks the Centers for Medicare & Medicaid Services (CMS) for the opportunity to provide comments in response to Medicare Drug Price Negotiation Program: Draft Guidance, Manufacturer Effectuation of the Maximum Fair Price in 2028 (Draft Guidance). CMS issued this draft guidance to describe the processes and requirements for manufacturer effectuation of the maximum fair price (MFP) in 2028 for selected drugs payable under Medicare Part B and/or covered under Medicare Part D.
The Academy of Managed Care Pharmacy (AMCP) thanks the Department of Health and Human Services (HHS) for the opportunity to provide comments in response to the Request for Information: Categories Used in Federal Vaccine Recommendations and the Role of Shared Clinical Decision-Making (RFI).
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