Letter to CMS: CAHC Opposition to International Pricing Index for Part B Treatments

The Honorable Seema Verma
Administrator
U.S. Centers for Medicare & Medicaid Services

RE: CMS-5528-ANPRM; CAHC Comments on Advanced Notice of Proposed Rulemaking: Medicare Program; International Pricing Index Model for Medicare Part B Drugs

Dear Administrator Verma:

The Council for Affordable Health Coverage (CAHC) is pleased to respond to the Centers for Medicare & Medicaid Services’ (CMS) Advanced Notice of Proposed Rulemaking (ANPRM) regarding an International Pricing Index (IPI) model for Medicare Part B Drugs. CAHC is a broad-based alliance with a singular focus: bringing down the cost of health care for all Americans. Our membership reflects a broad range of interests—organizations representing insurers, PBMs, patient groups, small and large employers, life science companies, consumers, and physician organizations.

The comments expressed in this letter reflect the views of the Council, and may not reflect those of our individual members.

CAHC’s staff helped write the laws that created the ASP, CAP and Part D models. Evidence shows the underlying laws are working to hold down costs, but adjustments are necessary to improve incentives and to recognize advances in policy and markets.

While CAHC has offered strong support for many of the policy solutions outlined in the administration’s

“American Patients First” blueprint for improving prescription drug affordability released earlier this year and appreciates CMS’s efforts to lower costs for Part B beneficiaries, we maintain deep concerns regarding an IPI model for these therapies. We support market-based solutions to lower total health costs, and the costs and prices of prescription drugs. We also seek to ensure patient access to care is maximized.