VBP Prop Rule Comment Letter

The Honorable Seema Verma, Administrator
Centers for Medicare & Medicaid Services
U.S. Department of Health and Human Services

Re: Medicaid Program; Establishing Minimum Standards in Medicaid State Drug Utilization Review (DUR) and Supporting Value-Based Purchasing (VBP) for Covered Drugs in Medicaid, Revising Medicaid Drug and Third-Party Liability (TPL) Requirements

Dear Administrator Verma:

Thank you for the opportunity to provide comments on the Medicaid Program; Establishing Minimum Standards in Medicaid State Drug Utilization Review (DUR) and Supporting Value-Based Purchasing

(VBP) for Drugs Covered in Medicaid, Revising Medicaid Drug Rebate and Third Party Liability (TPL) Requirements Proposed Rule.1

The Council for Affordable Health Coverage (CAHC) is a broad-based alliance with a singular focus: bringing down the cost of health care for all Americans. CAHC promotes policies that lower health costs through increased competition, informed consumers and more choices. Our members include providers, patient groups, insurers, pharmaceutical manufacturers, pharmacy benefit managers (PBMs), and employers. To that end, because of our diverse membership and the wide implications of the proposed rule, our comments apply only to the proposed rule’s effects on value-based purchasing arrangements (VBPs) for pharmaceuticals.

CAHC is supportive of CMS’ efforts to provide a path for VBPs, which are an important step forward in innovative contracting that bases reimbursement on whether or not a therapy works. They hold the promise of precision medicine by enabling patients, prescribers and payers to coordinate collecting outcomes data to match the right therapy to the right patient.