January 17, 2018

The Pharmaceutical Care Management Association (PCMA) released the following statement on recently submitted comments to the Centers for Medicare & Medicaid Services (CMS) regarding the Medicare Parts C and D proposed rule and request for information (RFI):

“Since its inception, Medicare Part D has been a bright spot in American health care, offering generous, affordable coverage to more than 42 million beneficiaries. The program has routinely delivered low premiums and high satisfaction for the nation’s seniors and disabled.

PCMA supports many provisions in CMS’ proposed rule, such as regulatory relief, and allowing flexibility for all Part D plan sponsors to promote the use of lower cost generics and biosimilars. However, PCMA has concerns with the proposed rule’s reinterpretation of ‘Any Willing Pharmacy’ and the RFI’s point-of-sale pharmacy price concession ideas, which put at risk the affordability and choice of preferred pharmacy plans – the most popular and widely chosen plan options in Part D. Three out of four seniors are enrolled in Part D plans featuring lower-cost pharmacy options.

After thoroughly reviewing the ideas in the RFI, we agree with CMS’ initial assessment that requiring plans to apply manufacturer rebates and pharmacy price concessions at the point of sale would increase premiums, raise taxpayer costs by billions of dollars, and give brand drugmakers a windfall in excess of $29 billion over the next 10 years.

The fundamental problem is these ideas focus on micromanaging how plans use existing price concessions for Medicare beneficiaries, but do nothing to reduce high prices set by drugmakers and imperil efforts to improve pharmacy performance. We see no way to implement the ideas in the RFI without increasing costs to the program and most of those it serves.”