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.