The AAMC Dec. 31, 2018, submitted comments on the Centers for Medicare and Medicaid Services’ (CMS) advance notice of proposed rulemaking (ANPRM) titled, “International Pricing Index Model (IPI Model) for Medicare Part B Drugs.” The AAMC supports efforts to address skyrocketing drug prices. However, the association’s comments express concern that the IPI Model, as outlined in the ANPRM, would result in increased regulatory and financial burden on hospitals.
The IPI Model includes several proposals on how to change the way Medicare pays for some Part B drugs and biologics. The AAMC’s comments highlight that the model could jeopardize the 340B Drug Pricing Program, a program that is essential for safety net hospitals’ ability to provide access to services for vulnerable populations. The AAMC does not support any proposal that puts this important program at risk. The association urged CMS not to restrict any hospital’s ability to continue to acquire Medicare Part B drugs that would be included in the model through the 340B program.
The IPI Model would create a new drug acquisition and distribution channel for certain high-cost Part B drugs. The AAMC questions whether replacing Medicare’s existing reimbursement structure with a proposal that would change how hospitals procure a small number of Part B drugs, as well as introducing an additional intermediary with whom hospitals will have to contract, will achieve a significant reduction in drug prices. In light of the complexity of the model and limited details in the ANPRM, the AAMC’s comments express concern that the IPI Model would disrupt the current Part B drug acquisition process without achieving the projected savings.
Before publishing a proposed rule, the AAMC requested that CMS work with hospital and physician stakeholders to identify ways to achieve the goal of reducing drug prices without increasing the regulatory and financial burden on hospitals that could jeopardize beneficiaries’ access to needed services and medications.