CAHC submitted comments to the CMS Draft Guidance on the 2027 Initial Price Applicability Year (IPAY) of the IRA’s Maximum Fair Price (MFP). In our comment letter, we focused on three specific areas:
- CMS is aggregating different products to make them subject to drug price controls, likely in violation of the law
- CMS must take steps to make lower prices available to patients at the pharmacy counter through a system that facilitates data and transactions
- The negotiation process should be transparent and accountable to patients and the public