AMCP Comment Letter on Biosimilar Interchangeability with a Biologic Reference Product

The Academy of Managed Care Pharmacy (AMCP) thanks the Department of Health and Human Services, the Department of Labor, and the Department of the Treasure (collectively, the Departments) for the opportunity to provide comments in response to the proposed rule titled “Enhancing Coverage of Preventive Services Under the Affordable Care Act [CMS 9887–P]” published in the Federal Register on October 28, 2024.

The Academy of Managed Care Pharmacy (AMCP) appreciates the opportunity to provide feedback on the “Medicare $2 Drug List Model” issued by CMS.

On November 21, the New York Department of Financial Services (DFS) announced sweeping market conduct regulations for pharmacy benefit managers (PBMs) serving health plans in the state. The DFS rule implements a landmark 2021 bill, S. 3762/A. 1396, which imposed restrictions on PBM contracts with health plans and pharmacies and established consumer protections. This action follows previous DFS rulemaking that created a broad definition of pharmacy benefit management services, required PBMs operating in the state to obtain a license, and established annual reporting requirements.