WASHINGTON, DC - In comments submitted to the Centers for Medicare and Medicaid Services (CMS), the American College of Rheumatology (ACR) urged the agency to proceed with caution when considering the International Pricing Index (IPI) drug pricing model, which was announced in an Advance Notice of Proposed Rulemaking in October. The ACR is concerned that, without substantial changes, the demonstration program could disrupt patient access to care, worsen the rheumatology workforce shortage and exacerbate geographic disparities in access to medical care.
"We appreciate the opportunity to provide input on the proposed IPI model and are encouraged by the agency's efforts to make needed therapies more affordable for patients," said Paula Marchetta, MD, MBA, president of the American College of Rheumatology. "However, we believe that changes must be made to ensure the proposal does not result in significant disruptions in patient care for the 54 million Americans who live with a rheumatic disease."
Specifically, the ACR recommends that the IPI demonstration:
- Be voluntary. Participation in this demonstration must be voluntary for providers and must include a way for them to exit the program if they find themselves unable to meet the administrative and financial changes required. Furthermore, the proposed demonstration should be reduced in size and scope and encompass a significantly smaller percentage of Part B drug administration to avoid disruptions in patient care.
- Reduce financial risks and administrative burdens to physicians. In order to avoid disruptions in patient access to treatments, ACR opposes any increased risk to patients and practices as a result of the demonstration. The ACR is concerned that the proposal to have providers collect patient cost-sharing payments would create serious financial risk and administrative burdens for physicians, particularly those operating small practices. Instead, the ACR recommends that if third-party vendors are tasked with drug procurement and distribution under the proposed model, that they also collect the payments themselves or pay providers a fee for the cost collection. Other administrative changes were suggested in the ACR's comments.
- Measure the impact on patient access to inform future developments. CMS should continuously track and report measures such as prescription adherence, out-of-pocket costs, and disease outcomes throughout the demonstration to ensure the model does not compromise patient access or health outcomes in favor of lower costs.
Over the summer, the ACR released a set of policy principles that must be at the forefront of any policy effort aimed at reducing drug costs for chronically ill Medicare patients. These principles include prioritizing patient access to affordable treatments while ensuring steps are taken to support shared decision-making between patients and providers.
"The ACR is dedicated to ensuring that rheumatologists and rheumatology care professionals have the resources they need to provide patients with appropriate, high-quality care," Dr. Marchetta concluded. "We thank CMS for providing an opportunity to offer our input and we look forward to serving as a resource for the agency as it works to lower drug costs for Americans with chronic illnesses."
To view the comment letter, click here.
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 7,700 U.S. rheumatologists and rheumatology health professionals who are committed to improving healthcare for Americans living with rheumatic diseases.
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