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AAMC Submits Comments to HHS on Drug Pricing Blueprint

July 20, 2018

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Mary Mullaney, Director, Hospital Payment Policies

The AAMC July 16 submitted comments to Health and Human Services (HHS) Secretary Alex M. Azar II in response to the administration’s plan to lower prescription drug prices, “American Patients First: The Trump Administration Blueprint to Lower Drug Prices and Reduce Out-of-Pocket Costs.”

The blueprint outlines the administration’s priorities to tackle the problem of rising prescription drug prices and specifically solicits stakeholder feedback on the 340B Drug Pricing Program [see Washington Highlights, May 18]. The AAMC supports efforts to make prescription drugs more affordable. It does not believe that the 340B Program is a driver of high drugs prices. Instead, the association contends that proposals to undermine the program would be counterproductive to addressing access to affordable medicines.

The AAMC urges HHS to implement drug pricing reforms that address the problem at its source rather than reduce the scope of the 340B Program, which provides critical services to underserved communities at no cost to taxpayers. The AAMC offers the following recommendations to HHS:

Improve manufacturer transparency in drug pricing, including drug launch prices and systematic price increases, and increase competition among both brand and generic drugs;

  • Implement the final rule that outlines the calculation of the ceiling prices that drug manufacturers may charge for drugs purchased through the 340B Program and application of civil monetary penalties for violations; 

  • Rescind the changes to Medicare Part B reimbursement for drugs purchased under the 340B Program;

  • Lift restrictions on pharmacists informing consumers of cheaper drug alternatives;

  • Evaluate value-based purchasing proposals that meaningfully reduce prescription drug costs; and

  • Do not reduce payments for drugs strictly based on site of service in which they are administered.

In addition to its comment letter, the AAMC joined five other hospital associations in submitting a separate letter specifically addressing the 340B Program section of the blueprint.

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