The Inflation Reduction Act (IRA) is a truly significant piece of legislation and merits continued examination and focus. Following the success of our first IRA workshop in August, AMCP last week hosted its second workshop, convening stakeholders across health plans, pharmacy benefit managers (PBMs), manufacturers, and patient advocacy groups, to help unpack the complexities of the IRA and discuss what’s on the horizon. There certainly was a lot to discuss — since we last met, CMS released the list of the first ten drugs selected for negotiation, which was a long-awaited step forward, and began their patient-focused listening sessions on each selected drug.
Throughout the workshop, panelists and presenters explored the next steps for the IRA and the challenges they expect to face over the next year. For example, we heard from panelists representing pharmaceutical manufacturers who expressed concern about the lack of transparency and predictability in the guidance set by CMS for the Drug Price Negotiation Program. There is also a great deal of anticipation surrounding the announcement of the Maximum Fair Price (MFP) from CMS next September, as this new pricing benchmark will impact reimbursement beyond just Medicare. As of now, all eyes are on CMS given the quick implementation timeline that will be placed on manufacturers.
Payer panelists helped shed light on the operational challenges of implementing the Medicare Prescription Payment Plan (MP3), which represents a fundamental change in the administration of Medicare Part D. The implementation of MP3 may cause health plans and pharmacies to face financial burdens by requiring them to take on additional responsibilities. To mitigate this, panelists agreed that national associations like AMCP will play a key role in educating their members on how to navigate these challenges. We at AMCP pride ourselves on being an educational resource for our members, as well as the general public, and are certainly up for the challenge!
Finally, we closed out the workshop by exploring the legal landscape of the IRA related to pending lawsuits. Ross Margulies, partner at Foley Hoag, walked us through the nine federal lawsuits that have been filed to challenge the drug price negotiation provisions of the IRA. This is a space AMCP and its members will be watching closely and we’ll be sure to cover new developments on this front in future conversations.
Last week’s workshop didn’t resolve all the uncertainties surrounding the IRA as there is so much yet to be determined and several important milestones yet to come over the next few months. However, we hope these workshops help build momentum that moves us closer to a greater understanding of the implications IRA will have. All of us in managed care pharmacy have a constructive role to play in the implementation of this landmark law. Step by step, workshop by workshop, we at AMCP believe that we’ll have a better sense of how to do just that. The IRA is an important piece of legislation that will impact the lives of millions of Americans and we look forward to the continuation of our IRA Workshop Series in 2024.
Susan A. Cantrell, MHL, RPh, CAE
Chief Executive Officer
Published on Nov. 17, 2023
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