In partnership with the APA, the MPS submitted comments in response to a CMS proposed rule – Modernizing Part D and Medicare Advantage to Lower Drug Prices and Reduce Out-of-Pocket Expenses.  This proposal would weaken the six protected classes (anticonvulsants, antidepressants, antineoplastic, antipsychotics, antiretrovirals, and immunosuppressants) under Medicare Part D by allowing additional utilization management tools to be applied, specifically indication-based formulary design and indication-based utilization management. It also codifies an earlier proposal by CMS to allow for Medicare Advantage plans to apply step therapy to Part B drugs.

The MPS letter outlines several points, including:

• We strongly oppose CMS authorizing additional utilization management tools. We are also very concerned about applying the Part D proposal to existing therapy.
• No two psychotropic medications have the same therapeutic effect or identical duration and intensity characteristics.
• Having to clear the numerous administrative hurdles to deliver quality care takes valuable time away from patients. The proposal is counter to the Administration’s “Patients over Paperwork Initiative” and interferes with the patient/doctor relationship.