In comments submitted to the Centers for Medicare and Medicaid Services, the American College of Rheumatology urged the agency to proceed with caution when considering the International Pricing Index drug pricing model, which was announced in an Advance Notice of Proposed Rulemaking in October.
The ACR is concerned that, without substantial changes, the demonstration program could disrupt patient access to care, worsen the rheumatology workforce shortage and exacerbate geographic disparities in access to medical care.
Specifically, the ACR recommends that the IPI demonstration be voluntary for providers, and must include a way for them to exit the program if they find themselves unable to meet the administrative and financial changes required.
Further, the proposed demonstration should be reduced in size and scope and encompass a significantly smaller percentage of Part B drug administration to avoid disruptions in patient care, the agency said.
Citing the need to avoid disruptions in patient access to treatments, the ACR opposed any increased risk to patients and practices as a result of the demonstration. The agency is concerned that the proposal to have providers collect patient cost-sharing payments would create serious financial risk and administrative burdens for physicians, particularly those operating small practices.
Instead, the ACR recommended that if third-party vendors are tasked with drug procurement and distribution under the proposed model, that they also collect the payments themselves or pay providers a fee for the cost collection.
CMS should continuously track and report measures such as prescription adherence, out-of-pocket costs, and disease outcomes throughout the demonstration to ensure the model does not compromise patient access or health outcomes in favor of lower costs, the agency said.
Over the summer, the ACR released a set of policy principles it said should be at the forefront of any policy effort aimed at reducing drug costs for chronically ill Medicare patients. These principles include prioritizing patient access to affordable treatments while ensuring steps are taken to support shared decision-making between patients and providers.