NPC Comments on CMS Best Price and Barriers to Value-Based Arrangements

In comments submitted to the Centers for Medicare and Medicaid Services (CMS) on a proposed rule, the National Pharmaceutical Council (NPC) outlines how Medicaid Best Price poses a barrier to implementing value-based arrangements and hinders innovation in payment and delivery systems, which can make it difficult for patients to access new treatments like gene and cell therapies.

Biopharmaceutical manufacturers and payers are interested in using value-based arrangements to pay for these new therapies, which can involve payments based on meeting a particular health outcome, tailoring plans to a patient population, or using various other metrics. Ideally, payments could be made via a subscription model, over longer or agreed-upon periods of time, or in installments. In practice, CMS’s current Best Price rules make it difficult to test creative financing mechanisms.

NPC offers recommendations to address additional concerns with the proposed rule, such as resolving ambiguities and operational challenges, identifying less burdensome approaches, and protecting patient access to cost-sharing assistance to promote medication adherence.

Read NPC’s full comments on our website.