Since passage of the Inflation Reduction Act, PIPC has worked collaboratively with organizations representing patients and people with disabilities to amplify the perspectives of those with lived experience in the implementation of the Medicare Drug Price Negotiation Program.
In its ICR comment letter to the agency, PIPC reiterated the concerns outlined in an Open Letter signed by over 100 organizations representing patients and people with disabilities, cautioning against the agency’s use of data that devalues people with disabilities, individuals with serious chronic conditions, and older adults.
The letter also highlights that the new IPAY 2028 guidance does not adequately reflect statutory limitations on the use of quality-adjusted life years (QALYs) and similar measures given the revised approach proposed for IPAY 2028 that would no longer require submitters to clarify whether such measures are included in their evidence. Disclosure of the use of QALYs and similar measures already barred from Medicare’s consideration is a necessary step to keep these value judgments out of Medicare decision-making as intended by the law.
The letter also highlights that the new IPAY 2028 guidance does not adequately reflect statutory limitations on the use of quality-adjusted life years (QALYs) and similar measures given the revised approach proposed for IPAY 2028 that would no longer require submitters to clarify whether such measures are included in their evidence. Disclosure of the use of QALYs and similar measures already barred from Medicare’s consideration is a necessary step to keep these value judgments out of Medicare decision-making as intended by the law.
| pipc_ipay_2028_comment_letter.pdf |
