RE: Modernizing Part D and Medicare Advantage to Lower Drug Prices and Reduce Out-of-pocket Expenses
Dear Ms. Verma,
On behalf of more than 100,000 specialty physicians from 15 specialty and subspecialty societies, and
dedicated to the development of sound federal health care policy that fosters patient access to the
highest quality specialty care, the undersigned members of the Alliance of Specialty Medicine (the
“Alliance”) write in response to proposals aimed at modernizing Part D and Medicare Advantage.
Providing Plan Flexibility to Manage Protected Classes
In the proposed regulation, CMS states it will empower MA plans to institute more utilization
management for drugs in the protected classes. Additionally, MA plans will be empowered to exclude a
drug from formulary if the product is a new formulation or if a drug’s price rises more than inflation.
The protected classes were created to protect patients. The existing policy ensures that patients
suffering from debilitating and deadly diseases will not have to battle formulary exclusions and
aggressive utilization management by insurers. We are concerned that the proposed policy amendments
effectively eliminate this patient protection as a “punishment” for certain behavior by manufacturers.
Our members are practicing providers and, as such, we fully appreciate the challenge of high drug
prices. However, dismantling patient protections in a quest to affect manufacturers is unlikely to
accomplish our shared goal of a reduction in drug prices – and may seriously harm patients in the
process. We urge the Administration not to move forward with its proposed changes to the protected
classes.
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Read full letter here
