The Alliance submitted comments to CMS on the Medicare Program; Part B Drug Payment Model stating that it “disagrees with a broad sweeping change to the payment methodology for drugs and biologics…since there is no evidence to support the change.” The Alliance noted that it believes that the proposed rule focuses solely on costs rather than on the complexities of patient care. The Alliance urged CMS to go through a formal rulemaking process for Phase 2 instead of a sub-regulatory process – which is insufficient due to the complexity of the models being developed.

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