Advance Notice of Proposed Rulemaking: International Price Index Model for Medicare Part B Drugs CMS-5528-ANPRM

NOF on behalf of the NBHPI has submitted comments to CMS and HHS regarding proposed rules that could impact osteoporosis patients access to testing and treatment. The following comment letter was submitted on December 31, 2018:

Dear Administrator Verma:

The National Osteoporosis Foundation (NOF) is pleased to submit its comments to the above- referenced International Price Index Model (IPI Model) notice. NOF understands that the IPI Model would leverage both the waiver authority of the Center for Medicare and Medicaid Innovation (CMMI) and the statutory provisions authorizing a Part B drug Competitive Acquisition Program (CAP) to test changes in both how clinicians obtain Part B drugs and the Medicare reimbursement basis for those treatments. We have significant concerns that this proposal could have the unintended consequence of exacerbating real-world deficiencies in osteoporosis care for Medicare beneficiaries and, ultimately, increase rather than decrease the already-high cost and morbidity of fragility fractures.

Click here to read the full letter.