CLL Society’s submitted another comment letter to Centers for Medicaid and Medicare (CMS) calling out their lack of transparency on the full drug price negotiation process. Meaningful stakeholder input on the counteroffer process should have required more context, and CMS failed to provide details on the initial offer and negotiation program agreement. Patient advocacy organizations like ours need to know how their previous feedback on this issue is being incorporated into the initial offer, and whether manufacturers will be able to add the patient perspective into their counteroffer evidence as well.
In our letter, we also note the very real disconnect between CMS’ perspective on “Primary Manufacturers” and the real-world variability in their contractual arrangements that may prohibit some of these entities from submitting information and/or committing to a maximum fair price (MFP).
When patients are asked whether they prefer fair prices for their medications or the possibility of new treatments enabling longer and fuller lives, or even a cure for their cancer, patients want BOTH. This is why it is so important that CLL Society’s Policy Institute and other patient-centric organizations continue to fully engage with CMS as they are in the process of implementing the drug price negotiation program. Without our voice, trade-offs will likely reflect priorities that focus primarily on saving money rather than improving and saving lives.