ACS CAN: Efforts to Reduce Drug Prices Must Balance Affordability with Access to Innovation and Safety

July 24, 2020

Today President Trump signed executive orders on pharmaceutical rebates, prescription drug importation and an International Pricing Index (IPI) or “Most Favored Nation” Model. The following is a response to the executive orders from the American Cancer Society Cancer Action Network (ACS CAN).

“While we acknowledge the administration’s attempt to further examine new ways to tackle prescription drug costs, this must be done in a manner which balances affordability with access to innovation and maintaining safety.

“The executive order would direct HHS to complete its rulemaking on prescription drug rebates. We believe that the proposed rule holds promise, but more details are needed as noted in our previous comments. The proposed rule issued last year encouraged discounts at the point of sale where discounts can be shared with consumers. This would particularly benefit individuals who take high-cost drugs, like cancer patients and survivors, and those with total drug spending in the coverage gap (Medicare Part D). However, we noted that the proposal could cause Part D premiums to rise. We look forward to more details on how this plan can work to make prescription drugs more affordable for individuals on Medicare.

“Unfortunately, we are concerned that the prescription drug importation plan outlined in the executive order does not strike the critical balance between affordability and access to innovation and maintaining safety. The prescription drug importation plan does not include details on the robust safeguards necessary to ensure the safety of the prescription drugs imported into the U.S.  In our comments on the proposed rule in March, we noted that the proposal as outlined raises a number of serious questions about the administrative feasibility, safety and actual savings for consumers. Not only does this plan create significant safety concerns for patients, the prescription drug importation plan is unlikely to lead to cost savings, as establishing a program to provide for prescription drug importation would negate savings provided under the importation program. 

“While the executive order on the International Pricing Index (IPI) or “Most Favored Nation” Model is being held until August 24, we had serious concerns with the administration’s previously proposed IPI model. As noted in our comments on the IPI advance notice of proposed rulemaking, the IPI model failed to provide sufficient details to ensure that beneficiaries – particularly those in active cancer treatment – will have access to the medications needed for their cancer care. Unfortunately, this model, as proposed in the advance notice of proposed rulemaking, could make it harder for cancer patients, especially those living in rural areas, to find the right provider to treat their cancer with the right drug. Preserving uninterrupted access should also be paramount when considering tying U.S. drug prices to those in other industrialized countries.

“Today there are nearly 17 million cancer survivors living in the United States and this year alone, an estimated 1.8 million Americans will be diagnosed with cancer. Both cancer patients and survivors rely on drug therapies to treat their disease, prevent recurrence and treat side effects. As more innovative therapies become available, we need to ensure that patients who are likely to benefit from these advances can also afford them in order to achieve our goal of reducing death and suffering from cancer.

“We will look forward to seeing additional details of the policy changes that have been put forward.”

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