NPC Comments on CMS' Drug Price Negotiation Counteroffer Information Collection Request

As CMS develops the detailed steps involved in the agency's drug pricing processes, NPC's comments highlight key shortcomings in the agency's counteroffer information collection request (ICR). 

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NPC submitted comments to the Centers for Medicare & Medicaid Services in response to the CMS–10849 Information Collection Request for Drug Price Negotiation Process under Sections 11001 and 11002 of the Inflation Reduction Act (IRA), which outlines the information the agency will collect as part of manufacturers' written counteroffers. The comments focus on three core recommendations to CMS:

  1. Establish a transparent, replicable structure for CMS’s initial written offer.
  2. Provide opportunities for in-person CMS-manufacturer engagement before manufacturers’ submission of their written counteroffers.
  3. Remove inappropriate constraints while acknowledging response burden.
Read the comment letter