Washington, D.C.—Today the American Cancer Society Cancer Action Network (ACS CAN) submitted comments to the Department Health and Human Services (HHS) detailing ways in which proposed changes to Medicare Part D’s six protected classes could jeopardize cancer patients’ timely access to drug therapies.
The six protected classes policy was established more than a decade ago to ensure Medicare beneficiaries were able to access innovative therapies. Currently, Medicare Part D plan sponsors are required to cover all or substantially all drug therapies in the designated six protected classes to treat cancer, epilepsy, HIV/AIDS, mental illness and organ transplants. In November 2018 HHS announced a proposal to alter rules around Medicare Part D’s six protected classes to allow plan sponsors to use utilization management tools – including step therapy and prior authorization – to limit access to protected class drug therapies.
The comment letter details how cancer care often requires specialized treatment targeted at a patient’s specific tumor and that such treatments are rarely interchangeable. In addition, cancer patients frequently suffer from other serious medical conditions further narrowing the number of potential appropriate drug therapies. Imposing step therapy on these patients, the letter states, “can lead to patients not filling their prescriptions or underutilizing medications. Prescription drug noncompliance can lead to poorer health outcomes for the beneficiary as well as increased costs to the Medicare program.”
Additionally, the letter raises alarm about patient access to the latest therapies should plans be allowed to exclude new formulations of drugs, as well as what recourse patients would have if plans eliminate certain drugs because a manufacturer increases the drug’s price above the consumer price index; both of which would be allowed under the proposal. “We are concerned that this policy will harm beneficiaries who will no longer be able to access medically appropriate therapies.”
The comment letter comes as ACS CAN, along with nearly 60 patient and provider organizations, are running an ad campaign showing widespread opposition to the proposed policy changes and their potential risk to patients with serious medical conditions. The campaign will run in print and digital national and Capitol Hill publications through the first week of February.
Read the full comment letter.