ACCC Statement on the Most Favored Nation Drug Pricing Model

On November 20, the Centers for Medicare and Medicaid Services (CMS) released the Most Favored Nation (MFN) Model Interim Final Rule with Comment Period (IFC). While the Association of Community Cancer Centers (ACCC) acknowledges the effort of the Trump Administration to address rising drug costs, we strongly urge CMS to withdraw the MFN model.

A policy that ties Medicare payment for outpatient drugs to international prices, if implemented without broader payment reform and over an extended period, could have a devastating impact on cancer programs across the country. This proposal will reduce or eliminate these Medicare beneficiaries’ access to appropriate care and exasperate health inequities.

The MFN Model will limit all Medicare beneficiaries’ access to the latest cancer care. In fact, the rule acknowledges that a portion of the savings is attributable to beneficiaries not accessing their drugs through the Medicare benefit, along with the associated lost utilization.

In addition, ACCC believes that the MFN Model will disproportionately impact cancer programs and practices in rural and underserved areas that have a high proportion of Medicare patients. Programs in these areas, usually the only option for many beneficiaries, will close, consolidate, and reduce critical services with the decrease in reimbursement and the increase an administrative burden.

At the same time, cancer programs and practices have been, and continue to be, severely impacted by the COVID-19 Public Health Emergency. The MFN Model is set to begin on January 1, 2021. It is unreasonable and impractical for cancer programs and practices to be required to participate in a mandatory Model that will further hinder patient access to care and effective treatments during the current COVID-19 pandemic.

Addressing healthcare costs, including drug prices, is a necessary effort. However, major changes to Medicare’s drug coverage should only be undertaken with careful consideration as to how patient access to care will be impacted. Lowering Medicare Part B reimbursement rates, without addressing the need to increase reimbursement for services, will result in patients unable to receive essential care and treatment.

If you have any questions about our statement or would like to discuss in further detail, please contact Christian G. Downs, JD, MHA, ACCC Executive Director, at 301.984.9496 or cdowns@accc-cancer.org.