Public Release: 

Nine physician specialty groups caution HHS against proposed drug pricing changes

Shuffling part B drug coverage into the part D program and restructuring reimbursements for new drugs would jeopardize patient care, specialists warn

American College of Rheumatology

Washington, D.C. - Nine of the nation's leading physician groups - including the American College of Rheumatology, American Academy of Neurology, American Academy of Ophthalmology, and American Urological Association - joined together this week to urge the Trump Administration to reconsider some of the policy changes suggested in recent drug pricing proposals that would have negative effects on patient care.

"While are we are supportive of some concepts recently presented, we do have serious concerns regarding other policy suggestions," stated the groups. "We believe HHS should make policy proposals designed to reflect the needs of complex care patients, reduce administrative burdens, and increase access to care."

In a letter sent to U.S. Department of Health and Human Services Secretary Alex Azar, the groups cautioned that the Administration's proposal to consolidate certain physician-administered drugs covered under Medicare Part B into the Part D program while reducing physician reimbursements for new drugs below the current payment rates would create access issues and force patients to seek treatment in higher-cost sites of care.

Medicare Part B and D are distinctly different programs with differing formulary structures and cost sharing that would be difficult to consolidate without significantly increasing out-of-pocket costs for patients - particularly those who have no other option but to rely on biologics. And because Medicare Part D does not allow for supplemental coverage, patients would be on the hook for larger portions of these expensive biologic therapies.

The groups also warned that changing Medicare Part D formulary standards to require a minimum of only one drug per class rather than the current two could limit patient's access to the medical therapies judged to be the most effective choice by their physician.

Additional concerns centered on how the Administration's proposal to reduce physician reimbursements for in-office treatment from the current ASP +6% (which is actually 4.3% due to sequestration) to Average Sales Price (ASP) +3% would be damaging to patient access. By reducing physician reimbursements below the cost of obtaining and providing these complex therapies, many practices - especially small and rural practices that are unable to negotiate bulk discounts from manufacturers - may be forced to stop administering biologic therapies to Medicare patients altogether, the specialty groups warn. This would drive patients into more expensive and less convenient settings to receive needed therapies - if such alternatives even exist.

In their letter, the groups are supportive of policies that would lower drug prices while increasing access to vital medications, including:

  • Requiring Medicare Part D plans to apply a substantial portion of rebates at the point of sale;
  • Establishing a beneficiary out-of-pocket maximum in the Medicare Part D catastrophic phase providing beneficiaries with better protection against high drug costs;
  • Decreasing the concentration in the pharmacy benefit manager (PBM) market and other segments of the supply chain; and
  • Providing guidance from CMS on how drug-related value-based contracts and price reporting would affect other price regulations.

"Our organizations are dedicated to ensuring that physicians have the resources they need to provide patients with high-quality care," the letter concludes. "We look forward to being a resource to you and we welcome the opportunity to meet with HHS to discuss our concerns and positions in more detail."

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About the American College of Rheumatology

The American College of Rheumatology (ACR) is the nation's leading advocacy organization for the rheumatology care community, representing more than 6,400 U.S. rheumatologists and rheumatology health professionals. As an ethically driven, professional membership organization committed to improving healthcare for Americans living with rheumatic diseases, the ACR advocates for high-quality, high-value policies and reforms that will ensure safe, effective, affordable and accessible rheumatology care.

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