On Sept. 15, the House E&C Health Subcommittee held a hearing on H.R. 3164.
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.
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AMCP’s comments focus on provisions in the Proposed Rule that affect prescription drug payment and access to clinically appropriate therapies. AMCP has an interest in ensuring that Medicare payment and coverage policies promote transparency, control prices, preserve beneficiary access, and avoid fragmented incentives across care settings and benefit designs. AMCP encourages CMS to provide clear methodological explanations and monitor effects on beneficiary access and provider behavior.
On Aug. 28, AMCP responded to Senate HELP Chairman Bill Cassidy's 340B reform proposal.
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