“We are encouraged that the Administration’s Blueprint raises several proposals that would increase the use of pharmacy benefit management (PBM) tools to reduce costs in public programs.
We support using PBM tools in Medicare Part B and expanding available formulary tools in Medicare Part D and Medicaid. We also support the Administration’s efforts to expand value-based purchasing.
We urge the Administration to focus on proposals that are likely to reduce costs and move beyond those that the Centers for Medicare & Medicaid Services (CMS) has already determined will raise costs. The Administration calculated that imposing point-of-sale rebates in Medicare Part D would increase taxpayer costs by $42 billion. That proposal should no longer be considered a credible means to accomplishing the President’s goals.
At a time of rising drug prices, we think it would make no sense to undermine plans’ ability to negotiate rebates or other price concessions from drugmakers. That would raise costs while offering no corresponding benefit to either consumers or taxpayers. A study by Oliver Wyman, commissioned by PCMA, found that Part D premiums would have been 52 percent higher in 2018 without rebates.
There’s absolutely no evidence to support the notion that drug companies will lower their prices if they no longer offer rebates in Part D.
In addition, a legal analysis, included in PCMA’s comments on the Blueprint, raises significant concerns as to drug manufacturers’ ability to offer upfront discounts under current antitrust case law.”
Click here to read PCMA’s comments on the Blueprint.