Jack be Nimble, Jack be Quick
By Joe Pugliese

Twenty-eighteen ended with a federal judge on 12/14 making a partial summary judgement declaring the Affordable Care Act (ACA) unconstitutional and then just before Christmas, we joined other 340B covered entities in a conference call with CMS Administrator Seema Verma to discuss the agency’s International Pricing Index (IPI) proposal that would target the most expensive pharmaceutical products and set reimbursement based on the average market price from 10 countries around the world.

The pace of change or at least proposals is not slowing down as we get into 2019. On February 6th, the Department of Health and Human Services released a proposed rule that would prohibit PBM rebates. Read on in the newsletter for a summary of the rule. This is the latest attempt by the Trump Administration to tackle a significant health policy challenge that we know all too well – expensive drug prices and unaffordable out-of-pocket costs.

It is not clear which, if any, of these items will be enacted. The judge’s ruling on the ACA has already been appealed and may be overturned. As I understand it, the IPI policy is complicated at best and has met with resistance by many directions, including from the 10 countries that would go into the basket of prices. The last proposal seems like it has the best opportunity to be adopted. Even if it is that will certainly not be the last word on the topic; the private sector has proven to be faster and more nimble than the government in adapting to changes in the marketplace.

We can all agree that we are not certain what will come next. I hope we can also all agree that like our commercial competitors, we commit to being nimble, agile and ready to adapt to a changing environment. We will always make sure that patient care does not suffer and rather, we will ensure that our ability to maintain and expand patient care remains intact. One recent success was in California, where after significant advocacy from HTCs and the patient community, MediCal positively declared they recognized the value of the comprehensive care model for people with bleeding disorders. I was asked what I thought about this development and all I could say was it was about time! After HTCs were shut out in Florida and dumped in Arizona my simple response was “it was well overdue.” Congratulations to all of the HTCs in California that made a compelling case for supporting the comprehensive care model.

This success and the success the Alliance payer group is having on your behalf is creating additional opportunities. Opportunities generally have a short half-life; when they come knocking on your door, please say yes!

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