November 17, 2017

(Washington, D.C.) — The Pharmaceutical Care Management Association (PCMA) released the following statement on the Centers for Medicare & Medicaid Services’ (CMS) Medicare Parts C and D proposed rule:

“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.

While we are still reviewing the draft proposed rule, we are initially encouraged by provisions that promote the use of lower cost generics and biosimilars and make it harder for at-risk patients to go ‘drugstore shopping’ for opioids.

We are also encouraged CMS continues to allow plan sponsors the option to use the price concessions they negotiate with manufacturers and drugstores to reduce premiums and other costs.  According to CMS, requiring plans to estimate and apply manufacturer rebates at the point-of-sale would raise premiums by up to $28 billion and taxpayer costs by up to $82 billion over the next decade.  Such a requirement would also create a windfall for drugmakers, who would pay up to $29 billion less in donut-hole discounts.

If pharmacy price concessions were also required to be applied at the point-of-sale, taxpayer costs would increase by an additional $16.6 billion over the next decade, while premiums would rise by an additional $5.7 billion, according to CMS.

Notably, the proposed rule addresses both the point-of-sale rebates and direct and indirect remuneration (DIR) issues through a Request for Information (RFI) rather than a requirement.

At the same time, new any willing pharmacy requirements outlined in the proposed rule could put at risk the choice and affordability of preferred pharmacy plans – the most popular and widely chosen options in Part D.   Protecting the stability of those plan options should be a top priority for regulators.”