HHS Drug Reform RFI Aims to Help Patients Better Afford Cancer Drugs
ONS shared the perspective of nurses caring for patients (https://www.ons.org/sites/default/files/ONS_HHS%20Drug%20Reform%20RFI_July%2016_2018.pdf) who may struggle to afford cancer drugs in comments submitted to the Department of Health and Human Services (HHS) on its Prescription Drug Reform Request for Information (https://www.federalregister.gov/documents/2018/05/16/2018-10435/) (RFI).
The HHS RFI, released May 16, 2018, raised questions and sought public comment on a variety of proposals in the president’s “America’s Patients First (https://www.hhs.gov/sites/default/files/AmericanPatientsFirst.pdf)” blueprint and FY 2019 budget. In its comments, ONS praised the overall goal to improve patient affordability of medications but expressed concern and asked for further HHS clarification on some specific proposals.
To increase competition and lower drug prices, ONS supports greater access to affordable generics and biosimilars and encourages more education on oncology biosimilars so providers “better understand prescribing options for patients they treat, particularly if biosimilars are less expensive and achieve the same clinical outcomes.”
ONS has serious concerns about some of the Medicare drug negotiation proposals that could restrict or delay patient access to cancer drugs, including a Competitive Acquisition Program for Part B drugs (which inserts an outside vendor or middleman between patient and provider), moving Medicare Part B drugs to Part D (which has been shown in an Acumen study (https://www.cms.gov/Research-Statistics-Data-and-Systems/Statistics-Trends-and-Reports/Reports/downloads/Acumen_B_to_D_Final_Report_2011.pdf) to increase out-of-pocket costs for oral cancer drugs), limiting Part D formularies (to one medicine per class versus the current two, which could harm patients needing specialized cancer drugs), and any changes that would limit cancer drugs currently freely accessed in the Part D “protected classes.” ONS encouraged HHS to consider that Part B infused drugs, such as chemotherapy, require safe handling and should not be mailed to pharmacies like many oral medications. To better help patients afford Part D medications, ONS strongly urged HHS to move forward with a cap on Part D out-of-pocket costs.
Additionally, ONS asked for patient guardrails when restructuring complex Medicare policies to provide more drug rebate savings to patients. To reduce out-of-pocket spending, ONS supports a change in policy to allow copay discount cards in Medicare for brand drugs that do not have a lower-cost generic alternative. Also, ONS opposes pharmacy gag clauses that prevent pharmacists from notifying patients when a medication would cost less if purchased off insurance with cash.
Finally, ONS shared the important role of nurses and nurse navigators in helping patients “interpret and sort through information” impacting cancer treatment costs and decisions.