On Dec. 11, the ACC submitted comments addressing the Centers for Medicare and Medicaid Services’ (CMS) Direct-to-Consumer Drug Price Transparency proposed rule seeking to increase transparency around the prices set by manufacturers and provide beneficiaries with important information needed to make informed decisions.

The proposed ruling would require prescription drug manufacturers to post the Wholesale Acquisition Cost (WAC) for prescription drugs and biological products covered by Medicare or Medicaid in direct-to-consumer television advertisements if the list price of one month’s supply, or the usual course of therapy, exceeds $35. Manufacturers would be required to provide quarterly updates on the listed prices.

The College’s comments, guided by the recently approved ACC health policy principles for Patient Access to Prescription Drugs, support efforts to increase drug price transparency across the distribution chain, as well as the proposal to extend these transparency requirements in advertisements beyond television, such as radio, magazines, newspapers, websites and social networking sites.

The rule also solicits feedback on the creation of a billing code for drug price counseling by clinicians. While the ACC appreciates CMS recognizing the importance of clinician engagement with patients on the cost of their therapies, the College is concerned that the creation of a new payment code may create additional administrative burden and unintentionally reduce the incentive to engage in this necessary patient-clinician discussion.

Keywords: ACC Advocacy, Medicaid, Prescription Drugs, Biological Products, Medicare, Health Expenditures, Health Policy

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