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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