December 18, 2018
Dear Secretary Azar:
Consumer Action for a Strong Economy (CASE)represents the interests of all American consumers by promoting common sense, free-market policies. We appreciate this opportunity to comment on the Centers for Medicare and Medicaid Studies’ “International Pricing Index Model for Medicare Part B Drugs” proposal.
We admire your commitment to protecting American patients and creating a robust healthcare market that encourages choice, competition and transparency to help all Americans afford quality healthcare. The Trump Administration’s emphasis on this issue has helped to increase generic competition and removed regulatory burdens, decreasing the cost of bringing a drug to market and helping to ensure a competitive market for patients.
However, the current proposal to set limits on how much the government will pay for specific medications is in effect, implementing price controls. Worse still, since these limits would be based upon an international pricing index instead of any rational market factor,the government would create an economic imbalance and skew the incentives for future innovations in the pharmaceutical market. Price controls are not the answer.
Instituting price controls into Medicare Part B will immediately restrict access to cutting-edge and life-saving medicines for patients. We have seen this already, as the U.S. market has access to 95 percent of cancer drugs, like those which would be affected by this proposal, whereas the United Kingdom, Japan and Greece – all of which would be used as reference countries under this proposal – have access only to 74, 49 and eight percent, respectively. Access to these cures and this superior treatment is the reason that the U.S. leads the world in cancer survival rates. Instituting these caps would jeopardize access to those treatments.
Equally concerning is the long-term effects that this proposal would have on U.S. innovation and our global leadership in research and development. Currently, the majority of new cures are developed in the United States, while U.S. companies likewise invest more in research and development than their peers in other nations. Instituting price controls into Part B would have an immediate chilling effect and would obliterate the incentive to research and develop new cures as companies are forced to adjust to the new, skewed market.
In conclusion, we urge you to rethink and abandon this proposal. Our healthcare system needs less government intervention skewing the market, not more.