NICA Submits Comments on International Pricing Index Model to the Centers for Medicare and Medicaid Services
On December 28, the National Infusion Center Association (NICA) submitted its formal comments to the Centers for Medicare and Medicaid Services (CMS) in response to the administration’s advance notice of proposed rulemaking released in October, which outlined a potential International Pricing Index (IPI) drug pricing model. NICA urged CMS to proceed with caution when considering reform measures with potentially catastrophic implications for patients that would significantly reshape the way medications covered under Medicare Part B are acquired, distributed, and reimbursed for those required to participate in the model.
“Market forces and political dynamics continue to threaten the sustainability of the most economical care setting in which to receive biological medications,” wrote Brian Nyquist, MPH, NICA executive director. “As currently framed, the potential IPI model outlined in the administration’s advanced notice of proposed rulemaking would threaten the sustainability of patients’ access to outpatient infusion facilities across the country, both independent, community-based sites of care and hospital-based sites of care.”
In November, NICA began encouraging constituents to write to their legislators opposing the IPI model for Medicare Part B drugs. Over 2,000 letters were sent by constituents concerned that this proposal may limit the treatment options available for patients managing chronic conditions.
The IPI drug pricing model, which would launch in the spring of 2020, aims to lower prices by transferring the procurement, distribution, and billing of physician-administered drugs to private sector vendors.
NICA expressed concerns that patients’ access to care may be restricted, delayed, and/or disrupted due to the following aspects of the model outlined in the advanced notice of proposed rulemaking:
- The heightened administrative burden on provider offices to be reimbursed for care;
- Mandatory participation for providers without the option to opt-out if their practice’s ability to treat patients is jeopardized due to participation in the IPI demonstration; and,
- Increased involvement of middlemen in the medical benefit supply chain
If the administration decides to move forward with an IPI demonstration, NICA urged the administration to ensure that reform measures will not inadvertently disrupt access to care by implementing the following tactics:
- Developing a strategy in collaboration with advocacy organizations to ensure that patients will be able to get the care they need, including a contingency plan if a demonstration inadvertently restricts, delays, or disrupts access to care; and,
- Make provider participation voluntary, or allow providers to “opt out” if their ability to treat patients is jeopardized as a result of mandatory participation.
In lieu of restructuring key components of the Medicare Part B program, NICA suggested strategies such as site of care optimization and allowing the extension of manufacturer cost-share assistance programs to Medicare beneficiaries when there isn’t a less expensive and equally effective generic available.
On behalf of infusion providers and their patients, NICA praised the administration’s commitment to control the rising cost of drugs and out-of-pocket spending for patients. NICA concluded its comments by extending its expertise on the in-office infusion delivery channel as a resource for CMS as it continues to develop actionable reform.
The comment period on the advance notice of proposed rulemaking ended on December 31, 2018. Comments from groups like NICA will be considered, and a proposed rule is expected to be introduced in the spring of 2019.