PIPC Joins Over 80 Organizations Urging HHS Civil Rights Office to Ban QALYs Across Federal Programs
PIPC joined over 80 organizations in signing a letter to the HHS Office for Civil Rights commenting on the proposed rule implementing Section 1557 of the Affordable Care Act. The groups support a comprehensive proposed rule seeking to strengthen civil rights protections in federally funded health programs and HHS programs and agreed that the ability to access needed health care fully and free from discrimination is critical and requires action to support and strengthen existing nondiscrimination laws.
In a letter to the Institute for Clinical and Economic Review (ICER), the Partnership to Improve Patient Care (PIPC) submitted comments on ICER's draft evidence report on treatments for beta thalessemia.
In a letter to the Medicare Payment Advisory Commission (MedPAC), the Partnership to Improve Patient Care (PIPC) urged the commission to avoid reliance on discriminatory value assessment metrics as the basis for Medicare coverage policy. PIPC’s concerns stem from comments by MedPAC commissioners during the April 2022 public meeting where metrics of clinical and cost effectiveness were discussed, particularly the quality-adjusted-life-years (QALY) metric.
In a letter to the Institute for Clinical and Economic Review (ICER), the Partnership to Improve Patient Care (PIPC) offered feedback on ICER's assessment of treatments for COVID-19. PIPC expressed disappointment in ICER's model for failing to capture both the full societal benefits of COVID-19 treatments, as well as the impact these treatments have on health equity. The letter also criticizes ICER's decision to rely on the discriminatory quality-adjusted-life-years (QALY) metric.
PIPC Submits Comments to CMMI on Listening Session on Incorporating Beneficiary Perspectives into Model Testing, Implementation, and Evaluation
In a letter to the Center for Medicare and Medicaid Innovation (CMMI), the Partnership to Improve Patient Care (PIPC) offered comments on CMMI's Listening Session entitled "Incorporating Beneficiary Perspectives into Model Testing, Implementation, and Evaluation." PIPC Chair Tony Coelho applauded CMMI Director Liz Fowler for conducting the listening session, noting that PIPC looks forward to working with the Health Care Payment and Learning Action Network (LAN) to convey the importance of beneficiary perspectives and prioritize best practices that focus on patient-centered outcomes. PIPC also called on CMMI to establish a clear process for engagement with patients and people with disabilities.
In a letter to the Innovation and Value Initiative (IVI), the Partnership to Improve Patient Care (PIPC) submitted comments on IVI's draft model protocol on major depressive disorder (MDD). The letter notes that, as designed, the model is unlikely to be able to address the issue of treatment heterogeneity, suggesting that IVI broaden the question of how to estimate the accrual of "marginal value" from new therapies. PIPC also strongly encouraged IVI to cease using of the quality-adjusted-life-years metric (QALY) in its models.