PIPC submitted comments to CMS making the following recommendations in response to its proposed rule governing the program.
Read the full letter below:
- CMS should avoid one-size fits all value metrics such as the QALY.
- CMS should develop a formalized process to ensure continuous, robust engagement of patients and people with disabilities at multiple levels.
- Where high-quality patient data exists, like FDA Voice of the Patient Reports, CMS should use it.
- Using patient insights, CMS should clearly communicate how it intends to use the input it receives, and how that input is reflected in the final negotiated prices.
- CMS should solicit input from a variety of patients who rely on the treatments in question, including those in rural areas to ensure representation of the diversity of the patients and communities affected by the topic.
- CMS should ensure that opportunities for patient engagement are accessible.
- To gauge both successes and challenges, CMS should establish a structured process for continuous review and assessment of its engagement strategy and its holistic processes.
Read the full letter below:
| pipc_ipay_comments_8.17.pdf |
