Alliance Comments on the 2019 Policy and Technical Changes to the Medicare Advantage and Part D Prescription Drug Program Proposed Rule
The Alliance of Specialty Medicine urged CMS Administrator Seema Verma to take significant steps to ensure beneficiary access to specialty medicine and the providers that deliver specialty care through a series of recommendations in comments on the 2019 Policy and Technical Changes to the Medicare Advantage (MA) and Part D Prescription Drug Program proposed rule. The specialty coalition urged CMS to improve the Quality Rating System by establishing a number of new stars measures and implement a physicians’ experience survey with the aim of creating meaningful quality improvement incentives and differentiating plans based on the quality of specialty medical care. The Alliance also urged CMS to make a number of requirements to reduce the burden on physicians associated with MA medical record requests and modify its “Preclusion List” criteria, ensuring they are rigorous, objective and subject to notice-and-comment rulemaking. Finally, the Alliance responded to CMS’ request for information regarding the application of manufacturer rebates and pharmacy price concessions to drug prices at the point of sale, supporting a mandatory pass-through of price concessions and urging the agency to move forward with implementing such a policy.
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