The Partnership to Improve Patient Care (PIPC) and 34 organizations representing patients, people with disabilities, and older adults submitted a comment letter to the Centers for Medicare and Medicaid Services (CMS) on the third cycle of the Medicare Drug Price Negotiation Program.
The letter underscores the importance of patient engagement, particularly in decisions related to clinical effectiveness, unmet medical need, and therapeutic alternatives. The letter also urges CUS to avoid the use of value assessment metrics that restrict access to care.
Specifically, the letter offers the following recommendations:
"While we appreciate the steps CMS has taken to formalize an engagement strategy, further action is needed to ensure that patient voices are not only heard but integrated into decision-making, and that the agency relies on high-quality, representative sources of evidence."
Specifically, the letter offers the following recommendations:
- CMS should avoid one-size fits all value metrics.
- CMS should develop a formalized process to ensure continuous, robust engagement of patients and people with disabilities at multiple levels.
- 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.
"While we appreciate the steps CMS has taken to formalize an engagement strategy, further action is needed to ensure that patient voices are not only heard but integrated into decision-making, and that the agency relies on high-quality, representative sources of evidence."
| pipc_ipay_2028_comment_letter.pdf |
