The Academy of Managed Care Pharmacy (AMCP) thanks the Office of Management and Budget (OMB) for the opportunity to provide comments in response to the proposed rule titled Regulation for Federal Financial Assistance.
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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