ACCC Submits Comments to Administration's Drug Pricing Blueprint

On July 16, the Association of Community Cancer Centers (ACCC) submitted comments to the Request for Information (RFI) included in the administration's Blueprint to Lower Drug Prices and Reduce Out-of-Pocket Costs. The plan was released in May. 

In its comments, ACCC expresses support for the overarching goal to "bend the cost curve by improving care, providing the right care at the right time, reducing over-treatment and under-treatment, and reducing hospital admissions and readmissions." However, ACCC cautions that "any policy solution to rein in drug costs must preserve patients' access to—and ability to afford—quality cancer care and, relatedly, mitigate any impact on already reduced payment rates for cancer providers."

In brief, ACCC comments on the following concerns:

• If HHS goes forward with revitalization of the Competitive Acquisition Program (CAP), there must be sufficient modifications to the program to preserve patient access to drugs, maintain provider flexibility, and permit providers to choose whether to participate based on whether participation in CAP will help them best serve their patients' needs, and not in response to punitive reimbursement cuts.
• HHS should not impose Medicare Part D utilization management requirements on Medicare Part B drugs or move these drugs into Medicare Part D as doing so would reduce patient access and could increase costs to the Medicare program and patients. In addition, HHS should clarify how these changes would work in practice.
• HHS should ensure that payment rates reflect the true costs of providing care at a particular site of service.
• HHS should ensure that any proposals related to modifying the 340B Drug Pricing Program encourage all oncology providers to treat underserved patient populations.