Give me time off and I’m likely to find myself in over my head with a project of my own making. #cantstopwontstop. Like deciding to bake 120 giant cookies and then deciding that I didn’t like the look of half of them and starting over. Health policy took a backseat to cookies and scones for neighbors and fortune cookies just for fun. Not to mention the “read a book a day” program I found myself on.
If I had to think of a word of the year from a pharmaceutical perspective – it’s tangled. Companies are having to pull apart the impacts of the Inflation Reduction Act (IRA) in terms of negotiation, inflation penalties and Part D redesign along with Medicaid changes (eliminating the rebate cap and sometimes requiring manufacturers to pay Medicaid when their drug was used) and potential changes like Medicaid price stacking. And other business threats like state implementation of upper payment limits, importation, and march-in rights. All that on top of the usual day-to-day access concerns.
Tangled requires understanding the impact of any one of those issues and then knitting them together to see the bigger picture and implications. It’s a rough road ahead.
From a policy perspective, I’m looking ahead to some additional information to nerd out on …
340B decisions. So far the courts have said that manufacturers can limit the number of contract pharmacies that get the 340B discount but we’re waiting for more court decisions. It didn’t add up to a lot of savings so far (<$1B) but the limits have not been there for long.
Inflation Reduction Act (IRA) Negotiated Prices. Where will the prices for the 10 selected drugs land? Will it be formulaic with just the basic math of average rebate or non-federal average manufacturer price minus the % (25%+, depending on number of years since approval)? Will it be more aggressive?
What happens to CMMI? The Center for Medicare and Medicaid Innovation (CMMI) was dealt a public relations blow last year when it was found not to have saved money. Realistically – it’s a testing ground, an investment but politically, it’s a problem. I’m curious what, if anything, changes.
PDAB ROI. The state prescription drug affordability boards (PDABs) are well on their way in several states but they require so much effort to get off the ground. Is the juice worth the squeeze?
Political Talking Points. We’re in a presidential election year and healthcare is often up there on the dais. President Biden will try and remind everyone of the IRA wins (Part D redesign, negotiated prices) and movement toward supply chain security. President Trump will talk about how international prices remain lower and not enough is being done. Rhetoric will fly and I’m not sure it will influence anyone.
I’m looking forward to continuing with Apteka and seeing what this can turn into. If you have any suggestions, comments, etc. – let me know. jennifer@aptekapolicy.com
Happy New Year!