Prevent Blindness sharply opposes the Trump Administration’s finalization of its “Most Favored Nations” (MFN) rule, which will take effect in January 2021. As a patient advocacy organization, Prevent Blindness promotes policies that encourage patient-centered decision-making and consumer choice while mitigating over-utilization and over-consumption without harming accessibility. We believe policies should balance provider behavior with appropriate oversight mechanisms on purchasers, payers, manufacturers, and other players in the marketplace to ensure the responsibility to lower cost and improved access is borne by all stakeholders. The policies proposed under the Trump Administration’s MFN rule are not aligned with these principles.
Under this interim final rule, several changes would take effect including a mandate that all Medicare providers participate in the 7-year, nationwide demonstration program. The MFN rule would base the purchase price for a to-be-determined class of 50 injectable drugs payable under the Medicare Part B program (treatments that require a physician to administer) on the lowest cost paid by economically-similar countries in an effort to reduce overall costs to the Medicare program. These policies, as research from Avalere has shown, would result in fewer than 1% of Medicare patients seeing any reduction in their out-of-pocket costs. Additionally, these policies pose very real and serious threats to patients who need timely access to innovative treatments that protect their eyesight against progressive eye diseases such as age-related macular degeneration, diabetes-related retinopathy, or venous occlusive disease associated with macular edema.
Prevent Blindness has previously addressed similar proposals, and urged the Administration to work with stakeholder groups to ensure their proposals truly achieve cost-savings for patients without endangering the health of the patient. We believe the rushed nature of its implementation, without stakeholder input on several expanded policies, in the final weeks before President Trump leaves office is disappointing and represents an incomplete approach to policy development. Patients are already facing significant access challenges to vision and eye care as a result of the COVID-19 pandemic, and unfortunately will face even greater barriers to eye care under the policies of this rule.