NHeLP comments on Medicaid Prescrption Drug Rebate Program and Value- based Purchasing Proposed Rulemaking

Executive Summary

In a proposed rule, CMS seeks to expand value-based purchasing arrangements for prescription drugs in commercial plans and the Medicaid program. However, the proposed changes offer a cost-containment strategy with no safeguards to ensure that Medicaid enrollees can continue to access needed outpatient prescription drugs. NHeLP comments warn against“cost effectiveness” measures which are discriminatory or lead to unlawful health care rationing, and urge CMS to withdraw the proposed rule.

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