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CMS Drops Stacking Provision in Medicaid Drug Rebate Proposal


The Autoimmune Association, along with 31 other patient organizations, submitted a letter to request the Centers for Medicare & Medicaid Services (CMS) to withdraw the Medicaid Rebate Stacking Policy from Medicaid Drug Rebate Program (MDRP) to protect patients and providers access to medications. We are happy to report that on May 15 CMS responded and indicated that they are not finalizing the proposal regarding stacking at this time.

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With the proposed policy change, titled “Misclassification of Drugs, Program Administration and Program Integrity Updates under the Medicaid Drug Rebate Program,” the best price reporting mechanisms would change for manufacturers, posing a significant level of uncertainty in terms of access for patients. While the Autoimmune Association respects the intent of this policy, we had some significant concerns about potential unintended consequences. We are pleased CMS is instead working with pharmaceutical manufacturers to collect additional information related to best price stacking methodologies to better understand and inform future rule-making.

The letter, submitted in mid-April,  detailed that the signers had concern about medication manufacturers reducing or eliminating discounts in the supply chain, further causing ripples and ultimately causing risk for an untenable healthcare situation. Patients are already experiencing higher rates of step therapy and prior authorization, which are creating increased access challenges for many people. The letter encouraged CMS to withdraw this policy and work closely with patients and providers to ensure that well-intentioned policies truly benefit all stakeholders.

We applaud CMS for taking the time to collect more information and look forward to working together on policies that lower access issues and burden for patients in the future.

Further reading:

  • Full letter to HHS and CMS can be found here.
  • CMS Statement on Misclassification of Drugs, Program Administration and Program Integrity Updates Under the Medicaid Drug Rebate Program (MDRP) Proposed Rule (CMS-2434-P) can be found here.


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