A lot of attention has been on the drug price negotiation aspects of the Inflation Reduction Act (IRA), but the implementation of out-of-pocket smoothing is something to keep an eye on, said Adam Colborn, JD, of AMCP.
The out-of-pocket smoothing under the Inflation Reduction Act (IRA) has the potential to be a “sleeper issue,” said Adam Colborn, JD, associate vice president of Congressional Affairs, AMCP.
This transcript has been lightly edited for clarity.
Transcript
Reactions to the IRA have been very split. What have you been hearing about the negotiations?
I think what I'm hearing is the same thing that everyone else is hearing, which is, as you said, very split. What I tend to hear is that some folks will say this is not as significant as we thought it would be, and then other folks are saying this is more significant than we thought it would be. I think if you're CMS trying to evaluate how you did, that's probably a good sign.
A lot of the things that we're paying attention to with the IRA are really sort of outside of the negotiation space, as well. We're looking at the implementation of the out-of-pocket smoothing or the M3P, which is the Medicare Prescription Payment Plan that allows patients to opt in anytime of the year and smooth their payments out. There was a lot of uncertainty when that provision was first passed. CMS has since provided a substantial amount of additional information, educational materials, things like that, but this is a totally new program. I don't know of anything else anywhere that is like this, and I'm very curious to see what the operational aspect of that looks like. That may be something that is a little bit of a sleeper issue.
Certainly, the community pharmacists and retail pharmacists are paying a lot of attention to that, because they know that their pharmacists are going to be the frontline for many patients in explaining that. CMS recently put out a sort of a threshold for when someone is likely to benefit from enrolling in that program. The threshold is a single month prescription cost of $600 or more. I think we'll see a lot of maybe confusion among patients. There's going to be a lot of work that needs to be done not just by those retail and community pharmacists but from Part D plan sponsors, as well, to educate their beneficiaries about when this is going to work for them or when it's not going to be something that really benefits them. I'm watching that pretty closely. In addition to the negotiation piece.
I think on the negotiation piece, the big question mark are the various lawsuits. There are some other lawsuits that are pending right now related to, for example, prescription drug affordability boards that may also have implications for the IRA's drug negotiation program. So, I think there are a lot of different components to watch there, but to the extent that CMS could balance their computing interests, I think they struck a good balance.
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