Astellas submits comments to the CMS on proposed rule on Contract Year 2019 Policy and Technical Changes to the Medicare Advantage and Part D programs

Feb 20, 2018
Astellas submits comments to the CMS on proposed rule on Contract Year 2019 Policy and Technical Changes to the Medicare Advantage and Part D programs

On January 16, 2018, Astellas submitted to the Centers for Medicare and Medicaid Services (CMS) comments on the agency’s proposed rule on Contract Year 2019 Policy and Technical Changes to the Medicare Advantage and Part D programs.

Our comments outline a number of concerns with the proposal and urge the agency to reconsider the proposal, including:

  • We strongly support the inclusion of the Request for Information regarding passing some level of rebates through to patients at the point-of-sale. Astellas urges CMS to initiate rulemaking to put in place a Part D drug point-of-sale rebate policy as soon as possible.
  • We strongly recommend that CMS not finalize the proposed new limitations on tiering exceptions and remove the regulation allowing plans to refuse to consider tiering exceptions for specialty tier drugs.
  • We urge CMS to adopt a maximum out of pocket in Medicare Advantage (MA) Part D, similar to the maximum out of pocket caps included in MA Parts A & B.
  • We request CMS consider establishing a policy that would allow part D plans to offer beneficiaries, on a voluntary basis, a “balanced copay” financing option, which would even out their monthly cost-sharing payments.

Please find our full comments here.

Astellas submits comments to the CMS on proposed rule on Contract Year 2019 Policy and Technical Changes to the Medicare Advantage and Part D programs

Karl Uhlendorf is director of communications and stakeholder engagement at Astellas Pharma US, Inc. With a 20-year track record of leading diverse public affairs and editorial teams, he currently oversees Astellas’ government communications and stakeholder engagement program.

Prior to joining Astellas in 2014, Karl was vice president of communications and public affairs at the Pharmaceutical Research & Manufacturers of America (PhRMA), responsible for communications strategy and execution in support of the association’s federal and state advocacy priorities. During his eight years at PhRMA, he assumed roles of increasing responsibility and scope.

Prior to joining PhRMA, Karl was editorial director at FDC Reports/Elsevier Business Intelligence, publisher of “The Pink Sheet” and other leading trade publications dedicated to FDA-regulated industries. He began his career as a reporter covering biomedical research and health policy, parlaying the experience into a series of editorial leadership positions.

Karl is actively engaged with a wide array of health-related organizations, including PhRMA, the Biotechnology Innovation Organization, National Pharmaceutical Council, National Consumers League, HealthyWomen, WomenHeart, Research!America and Caregivers Action Network. He graduated with a Bachelor of Literature degree from Bates College in Lewiston, Maine.