Comments to CMS on Proposed $2 Drug List Model

Editor’s note: The attached comment letter was submitted to the Centers for Medicare & Medicaid Services (CMS) on Dec. 9, 2024.

Schaeffer Center Scholars commented on CMS’ Oct. 9, 2024, request for information on “Medicare $2 Drug List Model,” a proposed model that would cap a 30-day supply of select generic drugs at $2 for enrollees of participating Part D plans. The researchers make the following points:

• Transparent, simple plan benefits like the proposed model, as well as transparent cost structures throughout the system, have valuable impacts for the beneficiary and may help align incentives throughout the pharmaceutical distribution system.
• To ensure the program is as impactful as possible, CMS administrators should work with health plans and providers to make the list of medications as comprehensive as possible.
• CMS should add a set fee paid to plans for administrative costs, as well as a set rate paid to pharmacies for dispensing the generic drug. This would ensure that plans and PBMs are not incentivized to favor generic products not on the list and that pharmacies are adequately reimbursed.
• Expanding the program to include more expensive generics with higher cost-sharing would further simplify benefit design and help beneficiaries make informed choices.

Read the full comment letter here.