ACR Expresses Concern About International Pricing Index in Comments to CMS

Samantha DiGrande

The American College of Rheumatology (ACR) is apprehensive 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.”

In recently submitted comments to CMS, the American College of Rheumatology (ACR) expressed concern that the proposed International Pricing Index (IPI), announced November 2018, may disrupt patient access to care.

Specifically, ACR is apprehensive 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.”

The IPI proposal would allow CMS to implement a reference pricing structure over a 5-year period from 2020-2025, which would enable Medicare to more closely align its payment amount for selected Part B drugs with prices paid in other nations, as well as allow for private-sector negotiations of drugs. CMS believes that the proposal could generate 30% in cost savings, although this figure does not include the prices of biosimilars; instead, it only compares the prices of reference products.

ACR explained in its letter that although it does not have a policy on international reference pricing, the group does support Medicare using its authority to lower drug prices, but does not support mandatory demonstration projects.

“Our current policy is that we support Medicare having the ability to negotiate for reduced drug prices; however, there are many specific pricing mechanisms described in the [IPI] that the ACR cannot support without having specific details on the policy,” read the ACR comment letter.

The organization suggested several modifications to the program:

  • Making participation voluntary
  • Ensuring that providers have a way to exit the demonstration if needed
  • Keeping the proposed price reduction using Medicare’s authority (20% of target price per year for 5 years), as well as the planned increase in participant gross reimbursement from 4.3% to 6%
  • Providing incentives for participation in the model that could include increased gross reimbursement
  • Tracking the impact of the model on patient access, including access to Part B drugs, adherence to prescriptions, amount of out-of-pocket costs, and disease outcomes

“We appreciate the opportunity to provide input on the proposed IPI model and are encouraged by the agency’s efforts to make needed therapies more affordable for patients,” said Paula Marchetta, MD, MBA, president of ACR, in a statement. “However, we believe that changes must be made to ensure the proposal does not result in significant disruptions in patient care for the 54 million Americans who live with rheumatic disease.”

The ACR is not the only organization that has expressed concern about the index, as just last month 339 patient, provider, and caregiver groups, on behalf of the Part B Access for Seniors and Physicians Coalition, sent a letter to Congress encouraging lawmakers to block the implementation of the index.

Comments on the IPI model have closed, and CMS will aim to issue a proposed rule this spring.