May 9, 2016

Andrew M. Slavitt, Acting Administrator
Centers for Medicare & Medicaid Services,
7500 Security Blvd.
Baltimore, MD 21244-8016

Attention: CMS-1670-P

Dear Acting Administrator Slavitt:

Thank you for the opportunity to comment on the proposed rule for adjusting Medicare’s Part B Drug Payment Model. The National Committee for Quality Assurance strongly supports testing alternative drug payment designs that may reduce Medicare expenditures while preserving or enhancing quality.

Part B’s current policy of paying 6% over the cost of any drug reimburses clinicians more for using more costly drugs when less costly drugs may be as or more effective. This directly undermines Medicare’s strategy for paying clinicians based on the value of care provided when the additional revenue from prescribing higher cost drugs is greater than payments that reward value. It also harms patients financially with higher co-insurance for costlier drugs, and can harm patients physically when less costly drugs are more effective. The current policy must change.

Your proposal to test lowering the 6% to 2.5% plus a flat fee would greatly reduce incentives to prescribe higher-cost drugs and strengthen incentives for high quality, efficient care. This is particularly critical given the broad support among providers, payers and other stakeholders for moving Medicare and all of our health care system to paying for value instead of volume. It also is urgently needed as Medicare is now implementing the Medicare Access & CHIP Reauthorization Act that Congress overwhelmingly voted for specifically to pay clinicians based on value.

Arguments by some stakeholders who greatly profit under the current system that patients will lose access to needed drugs by reducing percentage-based add-on payments are baseless and, frankly, offensive. There is no objective, rational basis for offering percentage-based add-on payments at all.

We therefore urge you to go farther and test complete replacement of this perverse incentive with flat fees sufficient to cover clinicians’ administrative costs related to Part B drugs.

This is by far the best way to support the transition to paying clinicians based on the value of care and protect patients from unwarranted potential for physical and financial harm.

We commend you for your thoughtful and careful approach to testing better ways to cover Part B drugs and for considering our comments. Please contact Paul Cotton, Director of Federal Affairs, at (202) 955-5162 or cotton@ncqa.org with any questions.

Sincerely,

Margaret O’Kane,

President