President’s Proposal on Drug Affordability
Last week the president introduced a proposal to rein in the cost of prescription medications in the U.S. I commend the administration for prioritizing an issue that so acutely impacts those who have been diagnosed with cancer. ACS CAN is reviewing the proposal closely, as drug therapies play an integral role in cancer treatment. Access to affordable prescription drug therapies is a key determinant in successful cancer outcomes. Continued innovation is also paramount in our ability to make continued progress. Thus, as our nation pursues solutions to the cost issue, we must do so in a way that continues to incentivize future discovery.
Advances in research have improved our understanding of cancer at the molecular level – leading to the development of more precise detection and diagnostic tools and corresponding therapies that are able to more specifically attack cancer. If patients who are likely to benefit from these advances face barriers to accessing drug therapies due to affordability, our ability to reach a national goal of eliminating suffering and death from cancer is greatly hindered.
The administration’s proposal, American Patients First Blueprint (Blueprint), looks at a number of areas of potential cost savings to the health care system in addition to proposals included in the president’s FY19 budget. At this stage, the administration has laid out some high-level themes, including addressing high list prices for drugs and out-of-pocket costs for consumers. However, details are forthcoming. How these proposals work in practice, and most importantly how they impact patient access and affordability, will be critically important.
Upon initial review of the Blueprint, there some potential areas of promise, but also some areas of concern.
Areas of Promise
Out-of-pocket limits in Medicare Part D – As cancer is a disease that disproportionately affects older individuals, working to improve affordability in Medicare - the health insurance program that serves the majority of this community - is of utmost importance. Seniors and disabled Medicare beneficiaries are often on a fixed income. A patient’s share of the cost of medication can become a barrier to care. If patients can’t afford the price, they may split doses or skip their prescription altogether. Placing a cap on out-of-pocket costs for drugs covered under Part D could help to ensure cancer patients and survivors take their prescriptions as directed and have the best opportunity at the best outcome for their cancer diagnosis.
Rebates to Patients – If rebates at the point of sale are available to reduce the price of a drug, passing those savings on to the consumer could reduce out-of-pocket costs that can often be a barrier to a patient taking their prescription as indicated.
Elimination of Gag Rules – Consumers can’t be expected to make informed decisions about cost without accurate information. Removing a rule that prohibits pharmacists from letting a customer know when paying the list price of a drug would save them money will lead to cost savings for patients.
Global Investment in Discovery - Resolving the challenges of global investment in discovering new medicines is an important area as we look at ways to reduce drug costs. We encourage the administration to include this approach in their comprehensive consideration of these issues and welcome the opportunity to review proposals in this policy area.
Areas of Concern
Elimination of Protected Classes – Cancer is comprised of more than 200 diseases with a tremendous range of drug therapies to address the varying molecular and genetic makeups of each particular type of cancer. Antineoplastics, or cancer-fighting drugs, are included in the list of six protected classes in Medicare, which ensures that as research results in innovative therapies, patients have access to those promising treatments in real time through automatic inclusion on drug formularies. Removing the protected class distinction could result in Part D plans covering only a few cancer drugs on the entire formulary, which would lead to tremendous out-of-pocket vulnerability for cancer patients forced to pay the full freight of medications that are not covered for their particular cancer. And it could hinder patient access to particular treatments identified by a patient’s physician, as well as some of the newest and most innovative cancer therapies.
Moving drugs from Medicare Part B to Part D
- Patients Could Pay More and Face Barriers to Accessing Medications: Shifting drugs from Part B to Part D could result in increased costs for many patients. Under Part B, patients pay a deductible and cost sharing – which is often covered by a supplemental health plan. But under Part D, patients pay a deductible, coinsurance (or a percent of the drug cost), all costs in the donut hole, and coinsurance after they reach the catastrophic cap. With no out-of-pocket limit on cost sharing, cancer patients could wind up with bills for a drug they are taking for a long period of time that could force them to choose between their life and lifesavings.
- Safety Issues: Most Part B therapies are physician-administered, are often temperature sensitive and require particular handling, and have specific administration requirements that - if compromised – could undermine the efficacy of the treatment. Moving the drugs to Part D could impact how the drugs are administered with the potential to compromise patient safety.
ACS CAN plans to review details as they become available and provide feedback to the administration to ensure that changes that are made to reduce spending on drugs don’t do anything to erect barriers to development of or access to evidenced-based therapies that are so critical for people to treat and to survive cancer.
ACS CAN will further advocate for balanced approaches that continue to foster innovation that results in lifesaving therapies for the cancers that still cut short the lives of our loved ones. This work builds on the work we continue to do at the state and local level to improve formulary transparency and access to prescription drugs.
It is also imperative that this be just the first step in our national effort to address costs in the health care system. Drug prices are one piece of the health care pie. Addressing drug prices in a vacuum will leave patients vulnerable to other out-of-pocket costs and our ability to make progress against a disease that is expected to kill more than 600,000 Americans this year – 1,650 today – depends in large part on removing barriers to all health care.