Advocacy News

CMS Proposes New Part B Drug Payment Model

The purpose of this message is to provide information about the Trump administration’s recent announcement about Medicare Part B drugs and ask for your feedback on the proposal.

Regulation Information

On October 25, 2018 the Centers for Medicare & Medicaid Services (CMS) released an advance notice of proposed rulemaking (ANPRM) seeking feedback on a potential drug pricing model called the International Pricing Index (IPI) model.  This comment solicitation is in alignment with President Trump’s blueprint to lower drug costs and reduce out-of-pocket costs for patients.  This is not a proposed rule, but is an opportunity for public comment before a proposed rule is drafted.  CMS is considering issuing a proposed rule on the potential model in the spring of 2019. The IPI Model would start in spring 2020 and operate for five years, until the spring of 2025. ACR requests feedback on the following items.

Model Structure

• Model participation would be mandatory for the physician practices, hospital outpatient departments (HOPDs), and other providers and suppliers of Medicare Part B drugs in the designated geographic areas
• Designated geographic areas would encompass 50 percent of current Medicare Part B spending on separately payable Part B drugs
• The model would initially focus on single source drugs and biologicals
• Designated vendors would buy and bill for drugs while providers receive a flat fee for interoffice administering of drugs

Public Feedback

CMS is interested in public comments on several potential model components including

• phasing down the Medicare payment amount for selected Part B drugs to more closely align with international prices;
• allowing private-sector vendors to negotiate prices for drugs, take title to drugs, and compete for physician and hospital business;
• changing the current 4.3 percent (post-sequester) drug add-on payment to a set payment based on the ASP + 6 percent which would decrease should the price of the drug go down;
• providers would collect patient cost sharing and pay a fee to vendors; quality measures would be monitored by CMS;
• whether group purchasing organizations, wholesalers, distributors, specialty pharmacies, Part D sponsors, and potentially individual or groups of physicians and hospitals and/or manufacturers could perform the more flexible role of model vendor.

Timeline

If implemented, over the course of the model, CMS plans monitor and evaluate the impact of the model on beneficiary access to drugs, program costs, and the quality of care for beneficiaries.

• ANRMP released (October 25, 2018)
• ANRMP public comment deadline (December 31, 2018)
• Possible proposed rule (spring 2019)
• Comment period would be open for 60 days
• Comments would be reviewed by CMS/HHS staff
• Final rule would be published in the federal register (summer/fall, 2019)
• Demonstration would begin (January 2020)
• Demonstration would end (January 2025)

You can download the ANPRM from the CMS Newsroom.

ACR Engagement

The ACR opposes mandatory demonstration models in Medicare and has concerns about parts of the IPI model, while remaining committed to engaging with CMS.

The ACR is working with other patient and physician groups to understand the impact of such a model on rheumatology and other specialties that have a high utilization of Part B drugs.

The ACR will submit comments on or before December 31, 2018 with the input of the Government Affairs Committee (GAC) and Committee on Rheumatologic Care (CORC).

Share your Feedback

The ACR welcomes your feedback about this ANPRM, including specific technical concerns and suggestions that could prevent disruption of patients’ access to drugs under the proposed model. Please send your feedback to kamodeo@rheumatology.org.