Organizations reflecting a wide breadth of companies and organizations representing, among others, multiple healthcare sectors, employers and patients share concerns over the proposed Medicare Part D changes with CMS Administrator.
February 18, 2014
The Honorable Marilyn B. Tavenner, Administrator Centers for Medicare & Medicaid Services U.S. Department of Health and Human Services Attention: CMS-4159-P P.O. Box 8013 Baltimore, MD 21244-8013
Dear Administrator Tavenner:
Thank you for the opportunity to share our views on CMS’s proposed changes to the Medicare Part D prescription drug program. The undersigned organizations reflect a wide breadth of companies and organizations representing, among others, multiple healthcare sectors, employers and patients that share your commitment to a strong Medicare that meets the healthcare needs of its beneficiaries.
We are deeply concerned that the proposed rule is inconsistent with the spirit and purpose of Medicare Part D, represents unnecessary changes to programs that are already extraordinarily effective in containing costs and, most importantly, will severely impede beneficiaries’ access to affordable health plans and medicines. We urge you in the strongest terms to withdraw the proposed rule that would have unintended consequences for seniors and beneficiaries with disabilities.
As you know, Medicare Part D is an undeniable success story. The Part D program has maintained stable, affordable average monthly premiums, enjoys a 90 percent approval rating among beneficiaries, and has program costs that are more than 40 percent below original Congressional Budget Office projections.
The proposed rule threatens to disrupt the positive effect the program is having on beneficiaries’ health and the Medicare program as a whole. Each undersigned organization has concerns about specific provisions, but there are overarching issues on which we are unanimous in our objections.
First, the rule would significantly reduce beneficiaries’ choice of plans and medicines and lead to disruptions in care. Millions of seniors and beneficiaries with disabilities would lose their current plan of choice or face changes in coverage. Beneficiaries value choice in the Part D marketplaces, and a range of options promotes both competition and innovation in benefit designs that improve the way beneficiaries’ access their Part D benefits and services.
Second, it would fundamentally transform the market-based competitive models that have made the Part D program highly successful. The rule would dramatically expand the federal government’s role in Medicare Part D despite the fact that there is no compelling reason for doing so. Reshaping Part D in this way will neither improve quality and affordability, nor incentivize plan innovation.
Third, the proposed regulation will impose a large cost burden that will impede the ability of plan sponsors and other health sectors to continue offering affordable, quality care to patients. These new costs will drive higher premiums for millions of beneficiaries and lead to higher costs for Medicare without tangible gains in service or quality for beneficiaries.
And, finally, the timing of this omnibus proposed rule has created great uncertainty as many of our organizations and the companies we represent have already begun preparations for the 2015 plan year. Many of these organizations are also currently devoting significant resources to ensuring the success of the health insurance exchanges, and this would represent a tremendous additional burden. With the June bid submission deadline in mind, we urge you to withdraw the proposed rule in a timely manner in order to minimize disruption for beneficiaries when it comes time to make plan selections in October.
In summary, the Part D proposed rule will not only fail to achieve its intended goals but will reduce choice and impose higher costs on beneficiaries and taxpayers. Medicare Part D has succeeded beyond expectations in enhancing the health and well-being of enrollees. Weakening these programs will result in a less healthy patient population and, consequently, increased Medicare costs in the long term.
Consequently, we urge CMS to withdraw the proposed rule that, as written, would fundamentally undermine the success of the Part D program for beneficiaries. We look forward to working with you to assure that Medicare continues to offer affordable, high-quality health coverage and accessible medications. It is a privilege to work with you to meet the needs of current and future Medicare beneficiaries.
Sincerely,
Abcam Inc
Academy of Managed Care Pharmacy
Advocates for Responsible Care (ARxC)
Aetna
AIDS Alliance
AIDS Connecticut (ACT)
Alliance for Patient Access
Alzheimer’s and Dementia Resource Center
Alzheimer’s & Dementia Alliance of Wisconsin
Alzheimer’s Association, Inc. of Oklahoma
Amada Senior Care
America’s Health Insurance Plans
American Autoimmune Related Diseases Association (AARDA)
American Osteopathic Association
Amgen
Analtech, Inc.
Arizona Bioindustry Association, Inc. (AZBio)
Arizona Urological Society
Association of Black Cardiologists
Association of Community Cancer Centers
Asthma and Allergy Foundation of America
BayBio
Bio Nebraska Life Sciences Association
Biocom
BioForward
BioHouston
BioNJ
BioOhio
Bioscience Association of West Virginia
Biotechnology Industry Organization
BlueCross BlueShield Association
California Asian Pacific Chamber of Commerce (CalAsian Chamber)
California Healthcare Institute (CHI)
California Hepatitis C Task Force
California Senior Advocates League
California Urological Association
Cancer Support Community Central Ohio
Caregiver Action Network
Catamaran
Center for Lawful Access and Abuse Deterrence (CLAAD)
Centerstone
Central Florida Behavioral Health Network
Centro de Mi Salud, LLC
Chemistry Council of New Jersey
Cigna
Citrus Council, National Kidney Foundation of Florida
Colon Cancer Alliance
Colorado BioScience Association
Colorado Gerontological Society
Combined Health Agencies
Community Access National Network (CANN)
Community Health Action Network (CHAN)
Community Health Charities of Iowa
Community Health Charities of Nebraska
Community Health Charities of Wisconsin
Community Healthy Charities of Florida
Council for Affordable Health Coverage
CURE–The Bioscience Network of Connecticut
CVS Caremark
Decatur County Hospital
Deckerville Community Hospital
Delaware Academy of Medicine
Delaware BioScience Association
Delaware HIV Consortium
Delaware Public Health Association
Diabetes Community Action Coalition of Fulton County
Easter Seals
Easter Seals Iowa
Easter Seals Massachusetts
Elder Care Advocacy of Florida
Eli Lilly and Company
Embracing Latina Leadership AllianceS (ELLAS)
Epilepsy California
Epilepsy Foundation of East Tennessee
Epilepsy Foundation of Greater Los Angeles
Epilepsy Foundation of San Diego County
Epilepsy Foundation of Western Wisconsin
Express Scripts
FAIR Foundation
Federation of Families for Children’s Mental Health -Colorado Chapter
Filipino American Service Group Inc. (FASGI)
Florida Partners in Crisis
Florida State Hispanic Chamber of Commerce
Generic Pharmaceutical Association
Georgia Bio
Georgia Osteoporosis Initiative
Global Genes Project
Global Healthy Living Foundation
Global Pharma Analytics, Inc.
H.E.A.L.S of the South
Hampton Roads Technology Council
HealthCare Institute of New Jersey (HINJ)
Healthcare Leadership Council
Healthy Heritage Movement, Inc.
Heart Rhythm Society
Hep C Connection, Denver CO
Hepatitis Foundation International
Hospira, Inc.
Human Rights Campaign
Humana
Illinois Biotechnology Industry Organization—iBIO®
Indiana Health Industry Forum
Indianapolis Urban League
International Foundation for Autoimmune Arthritis
Iowa Biotech Association
Iowa State Grange
It’s About Me Breast Cancer Awareness Association
Johnson & Johnson
Kentucky Chamber
Kentucky Life Sciences Council
Kidney Cancer Association
Latino Diabetes Association (LDA)
Let’s Talk About Change
Licensed Professional Counselors Association of North Carolina
Life Sciences Greenhouse of Central PA
Lifelong AIDS Alliance
LifeScience Alley®
LPCA, the Licensed Professional Counselors Association of GA
Lupus Foundation of Florida, Inc.
Lupus Foundation of Mid and Northern New York
Macular Degeneration Support
Massachusetts Association for Mental Health
MassBio
Medical Oncology Association of Southern California, Inc
MedTech Association (NY)
Men’s Health Network
Mental Health America of Colorado
Mental Health America of Indiana
Mental Health Association in Tulsa
Mental Health Coalition of NC
Mental Health Systems
Merck
MichBio
Michigan Clinic
Michigan Lupus Foundation
Michigan Rural Healthcare Preservation, Inc.
Missouri Association of Osteopathic Physicians and Surgeons
Missouri Biotechnology Association
MOBIO
Molly’s Fund Fighting Lupus
Montana BioScience Alliance
NAMI Colorado
NAMI Georgia
NAMI Indiana
NAMI IOWA
NAMI Kentucky
NAMI Nebraska
NAMI Ohio
NAMI Oklahoma
NAMI Utah
NAMI-KC
National Alliance for Caregiving
National Alliance on Mental Illness
National Association of Health Underwriters (NAHU)
National Association of Hepatitis Task Forces
National Association of Manufacturers
National Council for Community Behavioral Healthcare
National Council of Asian Pacific Islander Physicians
National Council of Negro Women Inc., View Park – Los Angeles
National Down Syndrome Society (NDSS)
National Gay and Lesbian Task Force
National Grange
National Hispanic Medical Association
National Kidney Foundation
National Minority Quality Forum
National Osteoporosis Foundation
National Spasmodic Torticollis Association
National Tay-Sachs and Allied Diseases Association
NC Psychological Association & Foundation
NCBIO
Neurofibromatosis, Mid-Atlantic
New Mexico Biotechnology & Biomedical Association (NMBio)
Newark Senior Center
NewYorkBIO
NJ Mayors Committee on Life Sciences
North Carolina AIDS Action Network
Novartis
Nuclea Biotechnologies, Inc.
Ohio State Grange
OptumRx
Oregon Bioscience Association
Pacific Northwest Chapter of the Transplant Recipients International Organization (TRIO)
Parkinson’s Association of San Diego
Partnership to Fight Chronic Disease (PFCD)
Pennsylvania Bio
Pfizer Inc
Pharmaceutical Care Management Association
Pharmaceutical Research and Manufacturers of America
Playing For Life
Plaza Community Services
Prescription Assistance Network of Stark County, Inc.
Prevent Cancer Foundation
Prime Therapeutics, LLC
Psychiatric Society of Virginia
RAIN Oklahoma
Renal Support Network
RetireSafe
Rio Grande Valley Diabetes Association
Rocky Mountain Stroke Center
Rush To Live
Salud USA
Sanofi
SCBIO
SD Biotech
Sickle Cell Disease Association of Florida
SoCalBio
Society for Women’s Health Research (SWHR)
South Dakota CARES INC
StopAfib.org
Tech Council of Maryland
Tennessee Association of Health Underwriters
Texas Association of Business (TAB)
Texas BioAlliance
Texas Conservative Coalition Research Institute
Texas Healthcare and Bioscience Institute
The AIDS Institute
The ALS Association
The ALS Association, Tennessee Chapter
The Arc of New Jersey
The G.R.E.E.N. Foundation
Tuberous Sclerosis Alliance
U.S. Chamber of Commerce
United Way Association of South Carolina
US Pain Foundation
US Script
Virginia Bio
Wall-Las Memorias Project
Walmart
Washington Biotechnology & Biomedical Association (WBBA)
WellPoint
Western Section of the American Urological Association
Women Against Prostate Cancer
Wound Care Clinic – ESU, Inc
Note: The above list shows the list of signatories as of February 18, 2014. For an up to date list, visit www.MedicareToday.org
Cc: The Honorable Dave Camp
The Honorable Orrin Hatch
The Honorable Sander Levin
The Honorable Fred Upton
The Honorable Henry Waxman
The Honorable Ron Wyden