Proposed Medicare Competitive Bidding Program Rule Would Hurt Patients

Earlier in July, CMS released a proposed rule that makes some drastic changes to the Medicare Competitive Bidding Program (CBP). The CBP is flawed, and unfortunately the proposed rule that is meant to fix it would only make things worse for beneficiaries with diabetes.

What’s wrong with the CBP?

Medicare written on clipboard in front of computerThe CBP applies to certain durable medical equipment, including self-monitoring blood glucose supplies via mail order. When the CBP was created in 2011, the Centers for Medicare and Medicaid Services (CMS) thought that CBP would reduce out-of-pocket expenses for fee-for-services Medicare beneficiaries and would save the program money.

The CBP did drop prices (reimbursement for test strips dropped 72%), but over 95% of mail order diabetes suppliers were eliminated. This meant that beneficiaries had far fewer options for suppliers. CMS did not find there were any negative health consequences to having fewer suppliers, however, beneficiaries experienced difficulty in getting their supplies on time or at all.

Fast forward to 2014, when the National Minority Quality Forum (NMQF) performed a study to try to confirm CMS’s conclusions that Medicare patients with diabetes that are using insulin were not negatively impacted by implementation of the CBP. The NMQF study found that the number of beneficiaries who experienced disruption in receiving testing supplies rose by 58%. And if beneficiaries couldn’t get their testing supplies, then they couldn’t test their blood sugar, which could lead to serious consequences.

In the markets where CMS implemented the CBP, the NMQF study found that there were 42 additional deaths and twice as many hospitalizations as in unaffected markets. Clearly, the NMQF study found that CMS’s report (the one that said everything was fine) was incorrect.

Even with all this research that showed the CBP was harmful to beneficiaries with diabetes, in July 2013, CMS implemented CBP nationally for mail order supplies AND supplies obtained from retail channels. This move eliminated over 98% of suppliers that provide mail order diabetes supplies. Things haven’t gotten better since the program was implemented nationally. A preliminary study shows that disruption in supply availability has continued in all markets, and over ⅓ of beneficiaries on insulin are not acquiring testing supplies at all.

These beneficiaries are forced to make insulin treatment decisions

without knowing what their blood sugar is.

You can read DPAC’s statement on the CBP here.

Why Doesn’t the Proposed Rule Fix the CBP?

Testing blood sugarThe rule proposed in July of this year would, unfortunately, only make the problems worse. The rule would suspend the CBP on January 1, 2019. While the CBP does need to be reevaluated with a removal of diabetes testing supplies from competitive bidding altogether, the solution presented currently is not the answer.

When the program is suspended, the rule provides that any willing qualified supplier may continue to provide diabetes testing supplies. Suppliers of the best testing supplies will not be willing to operate “willingly” if they do not have more information about the return of the program, how they will be paid, and/or who they will be supplying long-term.

Because suppliers of the most accurate and trusted testing supplies will not continue supplying beneficiaries with their needed diabetes testing supplies, beneficiaries will lose access to testing supplies that they have been trained upon. Moreover, the likelihood of their existing mail order supplier continuing to provide these supplies is slim, creating yet another disruption of access.

What Can I Do?

CMS is accepting comments on the CBP proposed rule now. DPAC has done the hard work for you and written out a statement that you can alter and submit with just a few clicks. CMS needs to hear from patients that the competitive bidding program is not perfect, but stopping it under the proposed rule’s parameters makes it worse!

Click here to submit a public comment!

Time To Act

Congressional Diabetes Caucus Presses CMS on Testing Supply Accuracy

On August 27, the Congressional Diabetes Caucus sent a letter to the Centers for Medicare and Medicaid Studies (CMS) asking them to respond to the Caucus’s earlier letter addressing the accuracy of diabetes testing supplies.

This letter isn’t the first one.

The Congressional Diabetes Caucus, led by Congressman Reed and Congresswoman DeGette, first wrote to CMS in December of 2017. They asked then-Acting Secretary of HHS Eric Hargan to look into how accurate commonly used blood glucose meters were. The question was based off a report from the Office of the Inspector General which found that 61% (!) of test strips furnished to Medicare beneficiaries failed the study’s accuracy standards. The Caucus’s December letter asked Acting Secretary to look into what steps CMS and the Food and Drug Administration (FDA) were taking to make sure Medicare beneficiaries were receiving products that actually work. It also urged the Secretary to take action to implement and enforce produce performance standards for testing supplies.

Acting Secretary Hargan responded to the Caucus’s letter in January of 2018, but the response was pretty lackluster. The response letter outlined steps that FDA was taking to ensure product reliability, but did not go into any steps that CMS is taking to protect beneficiaries. In fact, in the response, Acting Secretary Hargan wrote that “to date [CMS] hs not detected any negative trends.” We find this difficult to believe since having inaccurate blood glucose readings can lead to incorrect medication dosing and have dangerous consequences. 

DPAC has been working on this issue for a while.The CEO of DPAC, Christel Marchand Aprigliano, gave expert testimony on Capitol Hill on July 20th, 2017 in support of bill H.R. 3271, helping to protect access to accurate meters for people on Medicare using the National Mail Order program. (There’s a separate article discussing Christel’s testimony and H.R. 3271 in detail) H.R. 3271 was rolled up into the Bipartisan Budget Act of 2018, so now CMS has to comply with providing enhanced reporting that will aid Congress and CMS in ensuring beneficiaries are receiving the diabetic testing supplies they need to manage their condition. This was a huge win, but the work is never done!

What’s new:

This follow up letter doesn’t let CMS off the hook. The Congressional Diabetes Caucus wrote that they “find it disconcerting that the agency tasked with ensuring that the nation’s elderly and disabled have access to quality healthcare items be satisfied with the furnishing of blood glucose test systems that clearly fail accuracy standards.” The letter asked CMS to “take immediate steps to ensure that CMS puts into place adequate safeguards to protect the lives and safety of Medicare beneficiaries.”

You can read the full letter here. Diabetes Caucus Letter Aug 2018

Send a thank you to the Congressional Diabetes Caucus!

We’re so glad that the Caucus is not settling for the dissatisfying answers CMS provided. This issue is extremely important as lack of access to accurate testing supplies could lead to disastrous consequences for beneficiaries. Join us in thanking the leaders of the Caucus by clicking below!

Click here to send a thank you Tweet to Reps. Reed and DeGette (Co-Chairs of the Caucus) and Reps. Brooks, Ruiz, Jenkins, and DelBene (Vice-Chairs of the Caucus)!

Why I Advocate: Laurel Garrison

Why I Advocate: Laurel Garrison

I lived to prevent other people from getting sick.  Then my toddler was diagnosed with a totally unpreventable, incurable illness. And my life was forever changed.

It was 2015.  I was enjoying a successful career as an epidemiologist at the Centers for Disease Control and Prevention (CDC).  My days were a constant barrage of emergency conference calls and last-minute trips to fight the latest outbreak. Twelve-hour days were more the norm than the exception, and I’d often leave the house before my two children awoke and return after they’d gone to sleep.  My husband performed more than his fair share of the household duties.

All the while, my preschooler, and toddler were happy, healthy, and surrounded by people who loved them.  I did all the right things. I took prenatal vitamins (with Omega-3s!), bought organic food (and sheets, and clothes!), got them vaccinated (on time!), and bought all the internet’s best learning toys.

Photo by Sarah Green Photography

Then one night in December my 16-month-old baby girl was having trouble breathing.  I had taken her to the pediatrician twice that day, and when my after-hours calls went unreturned I drove her to the emergency department.  Everyone initially thought she had a respiratory virus. It was the winter after all. I was in shock when the doctor told me she had Type 1 diabetes.

We spent 24 hours in ICU and another three days in the hospital learning how to count carbs, calculate insulin dosages, and prick her finger to check her blood sugar.  I remember the first time the nurse asked me if I wanted to give her a shot, and “no” was not an option. We came home two days before Christmas. I realized then that our lives would never be the same.  Not just her life, but ALL of our lives. I couldn’t travel and put in all of those hours at work anymore. I needed to make her and my family my priority.

I threw myself into taking care of my daughter and the rest of my family.  I joined diabetes support groups. I went to conferences and diabetes family camp and fundraisers for diabetes research.  I poured over papers touting the latest in diabetes advancements.


There were big changes, like putting my career on hold to become a stay-at-home mom.  Or moving to another state to be closer to family and a good children’s hospital. There were sobering realities, for example, my daughter couldn’t go to preschool or summer day camps because they wouldn’t take her.  Normal everyday things changed too. We have to measure her food and have three well-balanced meals at the same time every day, always. We never get a break; she is with us 24/7 because we are the only ones who can administer insulin.  It’s impacted us financially as we went from a two-income household to one and now have the added cost of insulin and all the many other diabetes supplies she needs.  

The thing is, I had devoted my life to disease prevention, but there is absolutely NOTHING that anyone can do to prevent Type 1 diabetes.  Yet. And the incidence of the disease is increasing at an epidemic pace.

So until we can prevent it, I can help by giving diabetes a face and a story so people care.

I’ll tell our legislators about the everyday challenges so they can make informed decisions. I want my daughter to have the freedom to choose what she wants to do with her future without having to worry about keeping an affordable insurance plan.  I will be a champion for healthcare bills that give scientists the grants they need to do important research that will improve the lives of people living with diabetes. Maybe even one day that research will be the key to preventing it from happening to anyone else.


Announcing the 2018 Policy Training Meeting Attendees!

We are pleased to announce the attendees for the Fall 2018 Policy Training Meeting in Washington, DC!

These individuals will be attending an in-depth issue advocacy training and representing DPAC on October 1st for a joint day advocating on Capitol Hill along with medical professionals from the Endocrine Society. Along with members of our DPAC Patient Advisory Board, we’ll be welcoming:

[one_half last=”no” class=”” id=””]Paul U., Arizona

Mike R., Florida

Brooke B., Oklahoma

Emma G., Georgia

John C., D.C.

Cristina C., Washington

Gwen T., Louisiana

Nancy M., Florida[/one_half]
[one_half last=”yes” class=”” id=””]

Natalie B., Illinois

Leah W., Louisana

Alice D., Georgia

Nelea A., Kentucky

Daphne F., Louisana

Stephen S., Maryland

Rachel W., New Jersey

Jasmine G., Indiana


We want to sincerely thank everybody who applied – we had many amazing advocates to choose from! There will be additional opportunities to represent DPAC at these programs and others in 2019!

Show Your Support on Gag Clause Legislation to the Senate HELP Committee


The Senate HELP (Health, Education, Labor & Pensions) Committee will meet at 10am on Wednesday, July 25th to vote on legislation outlawing gag clauses which prevents pharmacists from telling you if a prescription drug you are picking up may cost less if you pay retail price than going through your insurance.

If you’re unfamiliar with what a Gag Clause is, you can learn more by reading here…

Or watching this quick video…

The bill is S. 2554 and it needs your help!

Fire up your Twitter account and send a message of support to all Senate HELP Committee members, asking them to vote YES and help patients.

DPAC has an email that you can send to your Senators, but this Twitter blitz will go only to the Senate HELP Committee members…and it needs to go out now – the meeting is Wednesday morning!

Simply click on each “Click to Tweet” and it will do all the work for you…


Please support bill S. 2554 Patient Right to Know Drug Prices Act, @GOPHelp and vote YES for patients on 7/25. #StopGagging Click To Tweet Please support bill S. 2554 Patient Right to Know Drug Prices Act, @HELPCmteDems and vote YES for patients on 7/25. #StopGagging Click To Tweet Please support bill S. 2554 Patient Right to Know Drug Prices Act, @SenAlexander and vote YES for patients on 7/25. #StopGagging Click To Tweet Please support bill S. 2554 Patient Right to Know Drug Prices Act, @SenatorIsakson and vote YES for patients on 7/25. #StopGagging Click To Tweet Please support bill S. 2554 Patient Right to Know Drug Prices Act, @SenatorEnzi and vote YES for patients on 7/25. #StopGagging Click To Tweet Please support bill S. 2554 Patient Right to Know Drug Prices Act,@PattyMurray and vote YES for patients on 7/25. #StopGagging Click To Tweet Please support bill S. 2554 Patient Right to Know Drug Prices Act, @SenPatRoberts and vote YES for patients on 7/25. #StopGagging Click To Tweet Please support bill S. 2554 Patient Right to Know Drug Prices Act, @RandPaul and vote YES for patients on 7/25. #StopGagging Click To Tweet Please support bill S. 2554 Patient Right to Know Drug Prices Act, @SenToddYoung and vote YES for patients on 7/25. #StopGagging Click To Tweet Please support bill S. 2554 Patient Right to Know Drug Prices Act, @SenBennetCO and vote YES for patients on 7/25. #StopGagging Click To Tweet Please support bill S. 2554 Patient Right to Know Drug Prices Act, @SenatorBurr and vote YES for patients on 7/25. #StopGagging Click To Tweet Please support bill S. 2554 Patient Right to Know Drug Prices Act, @OrrinHatch and vote YES for patients on 7/25. #StopGagging Click To Tweet Please support bill S. 2554 Patient Right to Know Drug Prices Act, @SenatorTimScott and vote YES for patients on 7/25. #StopGagging Click To Tweet Please support bill S. 2554 Patient Right to Know Drug Prices Act, @SenWarren and vote YES for patients on 7/25. #StopGagging Click To Tweet Please support bill S. 2554 Patient Right to Know Drug Prices Act, @SenTinaSmith and vote YES for patients on 7/25. #StopGagging Click To Tweet Please support bill S. 2554 Patient Right to Know Drug Prices Act, @SenSanders and vote YES for patients on 7/25. #StopGagging Click To Tweet Please support bill S. 2554 Patient Right to Know Drug Prices Act, @SenatorBaldwin and vote YES for patients on 7/25. #StopGagging Click To Tweet Please support bill S. 2554 Patient Right to Know Drug Prices Act, @timkaine and vote YES for patients on 7/25. #StopGagging Click To Tweet Please support bill S. 2554 Patient Right to Know Drug Prices Act,@SenDougJones and vote YES for patients on 7/25. #StopGagging Click To Tweet Please support bill S. 2554 Patient Right to Know Drug Prices Act, @SenBobCasey and vote YES for patients on 7/25. #StopGagging Click To Tweet Please support bill S. 2554 Patient Right to Know Drug Prices Act, @ChrisMurphyCT ‏ and vote YES for patients on 7/25. #StopGagging Click To Tweet Please support bill S. 2554 Patient Right to Know Drug Prices Act, @SenatorHassan‏ and vote YES for patients on 7/25. #StopGagging Click To Tweet

Thank you for helping raise the diabetes community’s voice on this issue!

CVS Caremark Formulary Change Makes Many Patients Switch Medications

CVS Caremark, a pharmacy benefit manager for many insurance plans, has changed its formulary as of July 1. The change comes in the middle of the year, when policyholders have no opportunity to choose a different insurance plan that may cover the drug or supply they use. This means that many patients who are stable on their medications and devices will now have to switch to a comparable product. This practice is forced non-medical switching at its worst.

A woman holds her head in frustration.

What CVS Caremark Changed

CVS Caremark has announced drastic changes to its formulary, or list of prescription drugs, devices, or supplies that they will cover. Some popular diabetes supplies affected by this change include all Humalog products (replaced with Novolog), Apidra (replaced with Fiasp), Lantus and Toujeo (replaced with Basaglar, Levemir, or Tresiba), all blood glucose test kits and test strips (replaced with OneTouch), and Jardiance (replaced with Farxiga or Invokana). See the full removal list here. 

The Impact of Forced Non-Medical Switching

Non-medical switching negatively impacts patients by disrupting their care and does not generate cost savings for the patient or the insurer. A recent NIH study found that patients who had been switched off their preferred medication had more doctor office visits, experienced new or worse medication side effects, and had problems with their new prescriptions not working.

Non-medical switching is even more complicated for people with diabetes because insulins on the market are not identical. When a patient is switched from one insulin to another, the patient’s dosing and administration requirements may change. DPAC has done several posts on non-medical switching. You can read DPAC’s statement, read a patient’s view on non-medical switching, and read a guest blog by Christopher G. Parkin.

Make a difference today!

MyMedsMyChoice logo

So what can you do? Several states have taken legislative action, and you can write a letter of support through DPAC if you live in Illinois, Pennsylvania,  or New York. (These states have bills in the state legislature that would change non-medical switching practices.) Just click on the state name to be taken to the action site!

If you’re not in one of those states, you can still do something! Consider contributing your story of being non-medically switched to My Meds My Choice, a survey for patients, caregivers, and healthcare professionals that will provide data on non-medical switching.

Finally, if your state is not considering legislation to ban non-medical switching, you can make a huge difference by setting meetings with your representatives and asking them to introduce legislation on this issue! You can use  DPAC’s statement as a jumping off point.


DPAC and Lions Clubs International Announce New Partnership!

DPAC and Lions Clubs International (LCI) are proud to announce a new collaborative partnership!

DPAC and LCI have signed a memorandum of understanding to collaborate on bringing diabetes policy issues to the U.S. national agenda.

Lions Clubs International held a Centennial Celebration in 2017-2018, and as part of that celebration announced diabetes as a new global signature cause. LCI will partner with DPAC in order to provide diabetes grassroots advocacy programming, education, and resources to over 1.4 million club members worldwide.

The Lions Club International Logo

Aligned Goals

Both DPAC and LCI are dedicated to expanding access to diabetes supplies, services, and education to address the growing global epidemic. Christel Marchand Aprigliano, DPAC’s Chief Executive Officer, is excited for the partnership. “We are honored to formally acknowledge our work with Lions Club International through this memorandum. Our commitment to share our knowledge and expertise in diabetes policy issues with passionate, dedicated Lions and Leos service members will bring new ideas and effective advocacy opportunities.”

A speech bubble with the words "we are dpac" inside

According to LCI president, Ms. Gudrun Yngvadottir, “Lions are uniquely qualified to take on the challenge and growing epidemic of diabetes. With over 1.4 million members around the world, we can make an impact by helping to increase public awareness, screening for diabetes, and providing one-on-one peer counseling to young people, in addition to working with partner organizations.”

To see the official press release, click here.

H.R. 5768 and S. 6633 Increase Access to Diabetes Self-Management Training!

On May 10th, Reps. Reed and DeGette introduced the “Expanding Access to Diabetes Self-Management Training Act” (H.R. 5768) to Congress. The Senate followed with S. 6633, introduced by Senators Shaheen and Collins, on August 22nd. These bills would provide avenues for people with diabetes to receive more diabetes self-management training (DSMT) through Medicare, and change the way DSMT is delivered. 

What is diabetes self-management training?

A woman testing her blood sugar

DSMT is a program covered by Medicare Part B designed to teach beneficiaries how to manage their diabetes. The training covers healthy eating, being active, monitoring one’s blood sugar, taking necessary medication, and reducing risks. The training is delivered by a doctor or qualified trained medical professional, and involves both individual and group sessions. Currently, Medicare covers 10 hours of DSMT per beneficiary, including 1 hour of individual training and 9 hours of group training. A beneficiary may also quality for up to 2 hours of follow-up training each year if it takes place in a calendar year after the year they got their initial training. In order to get DSMT covered by Medicare, the beneficiary must have a written order from their doctor.

What does H.R. 5768 & S. 6633 change?

approved rubber stamp

The bills would drastically increase Medicare beneficiaries’ access to DSMT services.

  • Referrals: The bills would permit physicians and qualified non-physician practitioners who are not directly involved in managing an individual’s diabetes to refer them for DSMT services.  
  • Hours: The bills would also allow the initial 10 hours of training during the first year to remain available until used up, and would allow 6 more hours of DSMT during the first year. After the first 10 hours are used, the bill would allow for 6 additional hours of DSMT each year.
  • Nutrition: The bills would also remove a current restriction that prevents DSMT from being delivered at the same time as Medical Nutrition Therapy. It makes sense to talk about diabetes and food at the same time!
  • Cost: The bills would exclude DSMT services from Part B cost-sharing and deductible requirements.
  • Community: The bills would change the Medicare Benefit Policy Manual to allow DSMT services to be provided in a community-based location instead of only medical offices.
  • Innovation: The bills would establish a 2-year demonstration of virtual DSMT, which could lead to Medicare coverage of virtual DSMT in the future.

Take Action!

These bills are a giant step forward in delivering DSMT to people who need it. The bills need cosponsors! Write to your representative and senators and ask them to support people with diabetes and cosponsor H.R. 5768 and S. 6633!

Click here to write a letter to your representative!

Click here to write a letter to your senators!

ANNOUNCEMENT: DPAC Policy Training Meeting Applications Accepted

DPAC is now accepting applications for the inaugural DPAC Policy Training Meeting, which will take place in Washington, D.C. from September 29 to October 1, 2018. Individuals impacted by diabetes who have a passion for policy advocacy and wish to have advanced training are encouraged to apply.


DPAC was founded to fill a gap in our community: a patient-first diabetes policy advocacy organization that focuses on safety, quality, and access. While we collaborate closely with other nonprofit organizations that help our community, the patient voice needed to be elevated. Over the past few years, DPAC has provided tools and resources to make policy advocacy easy to understand (and fun while learning about it!).

It’s time for the next step. The in-depth meeting will offer social media and public speaker training alongside education on policy issues our community currently faces and how to effectively advocate on a state and federal level. We’ll be bringing in experts and sharing best practices before we head up to Capitol Hill for our very first joint Hill Day.

Joint Hill Day

The Endocrine Society’s endocrinologist advocates will team up with our DPAC advocates to meet with members of Congress and their staff. Rather than research funding (which is what JDRF and ADA do best, so why reinvent the wheel?!) meetings, this Hill Day’s focus will be on policy issues and upcoming bills in Congress. By bringing patients and medical professionals together in the same meeting, it shows that we are united in our efforts to help all patients with diabetes.

What’s Involved?

Speaker Giving a Talk at Business Meeting. Audience in the conference hall. Business and Entrepreneurship.

For those who have shown an interest in policy advocacy and are selected to attend, DPAC will provide travel and lodging to Washington, D.C. to attend the meeting. Saturday and Sunday will be intensive training days (sorry – no time to sightsee!). Monday will be our Hill Day, and attendees will depart from the Hill to head back home.


And Then What?

The fun (and we hope it will be fun for attendees) doesn’t stop after the DPAC Policy Training Meeting. DPAC will be providing additional training and resources throughout 2019 to help these determined policy advocates in their own state. They may also be asked to speak in their state legislature (or come back to D.C.) on a diabetes issue. Diabetes policy advocacy isn’t a quick fix; we’re in this for the long-haul!

How Do I Apply?

Click here for the application.

Please take note of the application requirements and take your time answering the questions.

Applications will be accepted until FRIDAY, AUGUST 2nd.

DPAC will announce the first DPAC Policy Training Meeting attendees the week of August 13th. 

We hope you’ll consider applying and joining us in Washington, D.C. to advocate for our community!

Margaret Mead quote about changing the world,

5 Takeaways for Diabetes from the Blueprint on Prescription Drug Prices

A man holds his head in his hands with question marks above his head.

On Friday, May 11, 2018, HHS Secretary Alex Azar and President Trump gave quick speeches about how the United States would address drug pricing. At the same time, the Trump Administration published a their ideas: “American Patients First: The Trump Administration Blueprint to Lower Drug Prices and Reduce Out-of-Pocket Costs.” You don’t need to read all 44 pages (DPAC did this for you!) to know that none of the ideas proposed will help people with diabetes immediately, in the long-term, or at all.

Four Challenges & Four Strategies (According to the Administration)

The blueprint claims HHS has identified four challenges for the U.S. drug market:

  • High list prices for drugs
  • Seniors and government programs overpaying due to lack of negotiation “tools”
  • High and rising out-of-pocket costs for consumers
  • Foreign governments getting a “free-ride” off of American investment in innovation

And HHS has proposed four key strategies to reform:

  • Improved competition
  • Better negotiation
  • Incentives for lower list prices
  • Lowering out-of-pocket costs

5 Takeaways that Show the Blueprint Won’t Help The Diabetes Community

“Prices will come down.” – Donald J. Trump

  1. Prices will not come down any time soon, even if all of the immediate actions or “further opportunities” come to fruition within the next year (which will be impossible, with many of the actions needing legislation). The two single items that will help with out-of-pocket costs would be the elimination of the pharmacy gag clauses imposed by Pharmacy Benefit Managers (which DPAC supports – you can learn more AND send a message to Congress about this issue) and including information about price increases and alternatives in Medicare Part D explanation of benefits.
  2. “Increasing competition” for HHS means generic drugsnot the newer biologics, insulins, and brand name drugs that people with currently use. (Metformin, a popular diabetes oral medication, is already a generic drug that is inexpensive  – $4 at Walmart). Spurring competition for generic drugs does nothing to help the diabetes patient community with additional options.
  3. “Better Negotiation” is only for government programs, not individual or employer-a woman rubs her temples in frustrationbased insurance plans. If you’re on Medicare, next year’s budget will include a “closed formulary” which will require a minimum of one drug per category rather than two (which means less access to the drugs currently available, not more access). There is nothing in the blueprint about better negotiation for the U.S. population that does not have insurance (and doesn’t qualify for Medicaid) or has non-governmental insurance.
  4. The solutions for “Incentives for Lower List Prices” does not involve those in the supply chain responsible for list prices. The blueprint proposes a broad modernization of Medicare Part D (including a cap on the out-of-pocket maximum for Medicare Part D, which is good for many Medicare beneficiaries), and improving the 340B program. Again, nothing for the non-insured or non-governmental programs. Nowhere in the documents does it reference manufacturers, drug wholesales, insurance companies, pharmacy benefit managers, employers, or… patients. The U.S. government does not control list prices and does not offer incentives for anyone in the supply chain.
  5. There is no proposal to reduce out-of-pocket spending for most of the U.S. population. Once again, the focus is on the 340B drug program (which does not help the average consumer – it helps hospitals), applying “some” manufacturer rebates for Medicare, and getting those who are receiving Medicare low-income subsidies to receive biosimilars at a lower cost. In fact, with a push for moving many medications that are currently under Part B to Part D, prices for insulin negotiated by Medicare will be higher.

We’ll be watching to see how all of the proposed steps will shake out, but the first pass at helping the average American with the cost of prescription drugs is a miss.


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