The NHC appreciates the Administration’s goals to improve competition, promote better negotiation, lower list prices, and reduce out-of-pocket costs. We are committed to working with Congress and the Administration on drug pricing reforms that promote high-value health care, stimulate research and competition, and curb costs responsibly. Our comments on the proposed policies reflect our focus on issues impacting people with chronic conditions. In every aspect of the blueprint, we encourage HHS to consider how realized cost-savings can be applied to beneficiary cost-sharing requirements to reduce out-of-pocket costs for our nation’s seniors.
Many of the blueprint’s proposals are directly aligned with the NHC’s prior recommendations released last year, and this letter offers support and assistance in moving forward. Other portions of the blueprint offer promise, but lack of detail and uncertainty in how the proposal may be implemented make it difficult for the patient community to state whether we feel they will have a positive impact. In these instances, we look forward to greater clarity and opportunity for input. This letter also highlights a few areas where we urge caution about potential unintended consequences that may impact patient access.
The proposals included in the blueprint touch on a wide array of issues and impact all points of the research, development, and care delivery continuum. While multiple agencies within HHS will be tasked with implementing such changes to the health care system, we encourage coordination between agencies to ensure that there are no unintended consequences. The NHC also urges HHS and the various agencies to implement these proposals by first seeking input from the patient community and then utilizing the standard notice-and-comment process with ample time for comment. Finally, we encourage HHS to develop robust processes to regularly review the impact on patient access and report on the Department’s findings.