HHS has provided limited details on this “Most Favored Nation” model for Medicaid that it announced on Nov. 6, but the proposal raises fundamental questions about the potential for government reliance on quality-adjusted life years (QALYs), and the degree to which decisions about treatment choice and access will be made by government agencies instead of doctors and patients. PIPC believes it is vital for these questions to be answered, and for the administration to advance policies that do not rely on cost-effectiveness thresholds and that protect patients and people with disabilities who may not fit an average QALY-based assessment.
While this new model does not provide for an opportunity to public comment, we urge the administration to provide added clarification in the future. We welcome additional information on the administration’s intentions to analyze the impact of this new model on patients, including the impact on efforts to address unmet needs of patients through innovation.
On behalf of patients and people with disabilities, PIPC for many years has opposed the codification of discriminatory cost-effectiveness standards, which are set to meet the priorities of payers and government agencies, not patients. Stories from outside the U.S., like that of the Williams’ family, illustrate why QALYs have no place in U.S. policy. Patients do not have the luxury of time. Government policy that relies on QALYs and similar measures, whether directly or through reliance on other countries’ decisions, centers health care decision-making on payer priorities instead of patient needs.