ACP Expresses Support for Potential CMS Model That Sets $2 Copayment for Common Generic Drugs

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The proposed Medicare $2 Drug List Model includes a sample list of 101 generic medications, aims to improve medication adherence

Jan. 10, 2025 (ACP) -- The American College of Physicians recently provided a response to a request for information on the Medicare $2 Drug List Model, a model from the Centers for Medicare & Medicaid Services Innovation Center to make certain prescription drugs available to Medicare beneficiaries for a $2 monthly copayment or no more than $5 for a three-month supply.

“ACP supports the aim of the model, which is to improve the patient's ability to follow a medication plan and patient and prescriber satisfaction,” said Dejaih Johnson, ACP manager of regulatory affairs. “ACP will continue to monitor and engage in the development and implementation stages to ensure that the model empowers prescribers to select the most appropriate and affordable treatment plan for their patients and will not exacerbate administrative burdens, increase beneficiary premiums or restrict patient benefits in other areas.”

As Johnson explained, the $2 generics model is under development and would be offered by Part D plans that choose to participate. “It would build upon the success of existing drug lists used by large retail pharmacies with low, fixed prices,” she said. “The model was developed by evaluating generic drugs using multiple elements, such as frequency of use, drug cost, therapeutic role based on national treatment and medical society guidelines, prior authorization/step therapy requirements, inclusion in low-cost formularies by retailers and much more. The information was then reviewed by a technical expert panel of physicians, pharmacists and health policy experts, and their recommendations informed the selection of drugs included in the model.”

The ultimate goal is to test whether a simplified approach to offering low-cost, clinically important generic drugs can improve medication adherence, improve health outcomes and improve satisfaction with the Part D prescription drug benefit for people with Medicare and prescribers, Johnson explained.

Currently, the proposal includes a sample list of 101 medications across 15 clinical categories, including 35 drugs in the blood pressure/cardiovascular category, 14 in the behavioral health category and 12 in the infectious disease category.

“The current cost of prescription drugs varies by Medicare Part D plan and other factors, such as what stage of cost-sharing a beneficiary is in, whether they have a Medicare Advantage plan or not, how many months of supply they fill at once, whether coupons are available to lower the cost of their drug and more,” Johnson said.

She also noted that the model as proposed has an inherent flexibility built into it, meaning drugs can be added or removed from the list over time. This could happen as new generic drugs enter the market, when prescribing guidelines change or prices undergo sudden changes due to supply chain interruptions or other drug manufacturing variables.

“The Innovation Center has sought feedback on how best to develop this update process and has solicited input on how to best communicate model changes, complement existing formulary update processes and balance consistency in the drug list with the need to respond to immediate changes impacting accessibility to prescription drugs,” Johnson said. “ACP has urged the Innovation Center to ensure that prescribers and patients are informed timely of any changes to minimize interruptions in treatment. On a related note, ACP continues to work intently with lawmakers and the administration to urge broader prior authorization reform and step therapy requirements that similarly interrupt care and harm patients.”

The sample $2 Drug List shared in the request-for-information represents a starting point for the Innovation Center model development, which could be implemented as early as January 2027, according to the request for comment.

“ACP will continue to work with CMS, the CMS Innovation Center, lawmakers and the administration to ensure patients and physicians can and will benefit from the work to improve prescription drug affordability and access,” Johnson said.

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