Autoimmune Association Most Favored Nation Model (MFN) Statement of Concern

The Autoimmune Association is greatly concerned that the Most Favored Nation Model (MFN) Interim Final Rule released by the Centers for Medicare and Medicaid (CMS) on November 20th and set to take effect later this month will limit access and threaten innovation to critical medicines for our nation’s most vulnerable patients. As proposed, the MFN Model would be mandatory, last for seven years, and initially affect 50 drugs reimbursed under Medicare Part B. Much like the International Pricing Index (IPI) and other structures floated previously, the MFN would adopt prices set by a group of foreign countries that have very different, often discriminatory models for health care that often deny or delay coverage for medicines currently available to Americans with autoimmune diseases. Autoimmune Association understands that these reference nations employ Quality Adjusted Life Years (QALYs) in their calculations for health care coverage, value and cost which is highly discriminatory towards people with chronic conditions and disabilities.

Autoimmune Association supports efforts to improve access and reduce costs for autoimmune patients and all Americans. But MFN implementation without the opportunity for full public comment and appropriate consideration of potential negative consequences on access to current and future life-changing therapies for Medicare Part B patients and others puts these groups at risk for managing their health. Autoimmune Association urges the Administration to immediately withdraw the MFN Model interim Final Rule to avoid importing a pricing structure that is incompatible with the American health care system, patient needs, and national values. From a patient perspective, the MFN Model is not an equitable, effective, nor viable approach for truly promoting health and well-being for those with autoimmune and other chronic conditions and disabilities. Thus, Autoimmune Association encourages alternative, U.S.-based strategies for achieving savings in health care spending.