MDRP STACKING

National Poll Reveals Majority of Americans Are Concerned About How a CMS Medicaid Rule Will Harm Infusion Providers

National Poll Demonstrates Strong Support For Non-Hospital, Community-Based Infusion Centers Who Will Suffer as a Result of a CMS-Proposed Rule to “Stack” Medicaid Drug Discounts

AUSTIN, TX, March 14, 2024 – Today, the National Infusion Center Association (NICA) released results from a national poll of over 10,100 individuals conducted by Morning Consult. The poll surveyed participants on the value of non-hospital, community-based infusion providers and the potential impacts of a federal proposal to drastically change the way drug discounts are managed in the Medicaid program. The national poll found that two-thirds of Americans are concerned about the impact that a proposed Centers for Medicare and Medicaid Services (CMS) rule change regarding discount “stacking” could have on non-hospital, community-based infusion centers. The CMS proposed rule change to the Medicaid Drug Rebate Program would force drug manufacturers to stack or aggregate drug discounts provided to all stakeholders throughout the healthcare supply chain to determine the “best price,” including non-hospital infusion providers and pharmacies. If enacted, this CMS rule change could harm patient access to lifesaving medication, patient privacy, and future innovation in drug therapies.

Brian Nyquist, MPH, President and CEO of the National Infusion Center Association (NICA) stated:

“The Centers for Medicare and Medicaid Services (CMS) must heed the call from American voters, policymakers, and other concerned stakeholders and withdraw the proposed ‘stacking’ policy in the Medicaid Drug Rebate Program to protect infusion providers, the patients they care for, and the environment that enables continued innovation in infusion therapies.”

NICA is concerned that if the CMS rule is finalized, infusion providers will be unable to acquire and administer critical medications, forcing patients to forgo treatment or receive care in a higher-cost setting. Results from the poll demonstrate that Americans recognize the importance of non-hospital, community-based infusion centers and are seriously concerned with how infusion centers may be impacted by the proposed “stacking” policy. Key findings from the national poll of American voters include:

  • Two-thirds of adults are concerned about the impact the proposed rule will have on nonhospital, community-based infusion centers. 84% of those who identified as highly knowledgeable about infusion centers indicated they were very or somewhat concerned about the rule change.
  • American voters view non-hospital, community-based infusion centers as critical to the healthcare system and patients. 75% of polled Americans see non-hospital, community-based infusion centers as very or somewhat important to the healthcare system and patients.
  • Nearly two-thirds of adults polled agreed that protecting non-hospital, community-based infusion centers should be a priority for government officials. In the poll, 64% of respondents indicated that protection of non-hospital, community-based infusion centers should be important for government officials.

In February, the National Infusion Center Association (NICA) led a sign-on letter to Department of Health and Human Services (HHS) Secretary Xavier Becerra and Centers for Medicare and Medicaid Services (CMS) Administrator Chiquita Brooks-LaSure outlining the harm of the proposed “stacking” policy. The letter was co-signed by the American College of Rheumatology (ACR), American Gastroenterological Association (AGA), Coalition of State Rheumatology Organizations (CSRO), National Organization of Rheumatology Management (NORM), and the Rheumatology Nurses Society (RNS). The letter urges CMS to withdraw this proposal and work collaboratively with all stakeholders, including infusion providers, to develop policies that truly benefit patients without disrupting access, innovation, and patient privacy.

What Advocates Are Saying:

“While we commend CMS for continuing to propose solutions intended to reduce costs for Medicaid beneficiaries, every policy should be evaluated on its impact across the entire healthcare ecosystem to mitigate unintended consequences. It is imperative that CMS withdraw the stacking policy to protect providers and vulnerable patients who rely on access to essential treatments to optimize their health and well-being.” – Brian Nyquist, MPH, President and Chief Executive Officer (CEO) of the National Infusion Center Association (NICA).

“For instance, would the new best price rule reduce clinical and financial risk for Medicaid beneficiaries — who already face no or extremely low co-pays for prescriptions — or would it merely save the government money? And would those savings come at the cost of depressing investment in new and innovative treatments? The rule’s potential deterrent effect on drug research must not be discounted, especially since Medicaid recipients have higher rates of disabilities and chronic conditions than other covered individuals in the public and private sectors.” – Gary A. Puckrein, President & Chief Executive Officer Of The National Minority Quality Forum (NMQF)

“Incorporating the stacking of multiple discounts is not a determination of best price, but a commentary on a complex system that requires a multitude of transactions. Particularly for smaller innovator companies with limited product lines, this complex marketplace can be challenging to navigate. Incorporating aspects of not one but all transactions into the calculation of the best price can make bringing a potentially life-changing therapy to market even more challenging.” – Margarita Valdez Martínez, Director of Policy and Advocacy, American Society of Gene + Cell Therapy.