Medicare Payment Model

We thank the Centers for Medicare and Medicaid Services (CMS) for the opportunity to provide comments on the proposed rule Medicare Program: Part B Drug Payment Model (CMS-1670-P) published in the Federal Register on March 11, 2016. Under the proposed rule, CMS would implement a two-phase model to test whether alternative drug payment designs will lead to a reduction in Medicare expenditures, while preserving or enhancing the quality of care provided to Medicare beneficiaries. The first phase would involve understanding the impact of changing the current payment methodology for Part B drugs from Average Sales Price (ASP) + 6% to ASP + 2.5% + a flat fee. The second phase would involve understanding the impact of implementing value-based purchasing …show more content…
, 6) Cancer drugs in general because these drugs were/are created to extend life, 7) Rheumatoid Arthritis Part B drugs (e.g. TNF Inhibitors such as Remicade) and 8) Multiple Myeloma Part B drugs – bortezomib, carfilzomib, …show more content…
In conclusion, we applaud CMS for issuing the proposed rule on Medicare Part B drug payment models. We believe it is important to test the next generation of value based purchasing models that will help balance pharmaceutical innovation with affordability while having the patient at the center of care delivery. We believe that: 1) Value Based Purchasing tools will lead to better value and higher quality for patients, 2) the Part B Payment model will increase patient access and 3) the model should consider use of utilization management for Part B drugs.

Thank you for the opportunity to comment on this proposal. If you have any questions regarding the comments or would like further information, please contact me at