Comments: Advance Notice of Proposed Rulemaking: Medicare Program; International Pricing Index Model for Medicare Part B Drugs

We appreciate the Centers for Medicare & Medicaid Services (CMS) releasing this Advance Notice of Proposed Rulemaking (ANPRM) which contains thoughtful explorations of the causes of high drug spending in Medicare Part B drug coverage. CMS acknowledges that Medicare and its beneficiaries pay more for their drugs in general than other countries do and that the increase in Medicare drug spending over the past five years is largely due to increases in the manufacturer prices of drugs and mix of drugs for those beneficiaries who received them rather than increases in Medicare enrollment and drug utilization. We support the goal of finding mechanisms to bring down the cost of Part B medications for both Medicare beneficiaries and the Medicare program as a whole.