NASP Comments on CMS Most Favored Nation (MFN) Model Interim Final Rule (CMS-5528-IFC)

Feb 18, 2021 · Advocacy

The National Association of Specialty Pharmacy (NASP) submitted comments on the Center for Medicare and Medicaid Services’ (CMS) proposed rule, “Most Favored Nation (MFN) Model” at 85 Fed. Reg. 76180 (CMS-5528-IFC).

The Most Favored Nation (MFN) Model is a new Medicare payment model under section 115A of the Social Security Act. The MFN Model will test whether more closely aligning payment for Medicare Part B drugs and biologicals with international prices and removing incentives to use higher-cost drugs can control unsustainable growth in Medicare Part B spending without adversely affecting quality of care for beneficiaries.

NASP provided comments sharing the goal of reducing the cost of prescription drugs and supporting patient access to needed medications. However, NASP expressed significant concerns regarding the MFN Model approach. NASP urges CMS to withdraw the MFN interim final rule and the Centers for Medicare and Medicaid Innovation (CMMI) MFN Model program and work with the stakeholder community to ensure any future planned changes to the Part B drug program will not negatively impact patient access to specialty treatments. To read the comments, please click here.