Industry leaders reach out to CMS on proposed changes to Medicare Part D

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.




Abcam Inc

Academy of Managed Care Pharmacy

Advocates for Responsible Care (ARxC)


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


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


Bio Nebraska Life Sciences Association






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


Center for Lawful Access and Abuse Deterrence (CLAAD)


Central Florida Behavioral Health Network

Centro de Mi Salud, LLC

Chemistry Council of New Jersey


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


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


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



Michigan Clinic

Michigan Lupus Foundation

Michigan Rural Healthcare Preservation, Inc.

Missouri Association of Osteopathic Physicians and Surgeons

Missouri Biotechnology Association


Molly’s Fund Fighting Lupus

Montana BioScience Alliance

NAMI Colorado

NAMI Georgia

NAMI Indiana


NAMI Kentucky

NAMI Nebraska


NAMI Oklahoma



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


Neurofibromatosis, Mid-Atlantic

New Mexico Biotechnology & Biomedical Association (NMBio)

Newark Senior Center


NJ Mayors Committee on Life Sciences

North Carolina AIDS Action Network


Nuclea Biotechnologies, Inc.

Ohio State Grange


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


Rio Grande Valley Diabetes Association

Rocky Mountain Stroke Center

Rush To Live

Salud USA



SD Biotech

Sickle Cell Disease Association of Florida


Society for Women’s Health Research (SWHR)

South Dakota CARES INC

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


Washington Biotechnology & Biomedical Association (WBBA)


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

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




Posted in Advocacy and Regulations, AZBio News, Uncategorized.