Rebates and Medicare Part D

Amanda Forys, MSPH: CMS this past month put out their part D proposed rule, and they wanted to get some information from industry on the whole rebates scenario.

Right now, in part D, patients are getting their products and they’re going to the pharmacy, they’re paying what their plan’s co-payment is, and then on the back end, the payer is receiving in a lot of cases, a rebate from the manufacturer. The savings that the payer is getting is being translated each year when the plans submit back to Medicare what their monthly premiums are going to be for the next year.

So, the Medicare program says, “We’ve had very, very little growth in our part D premiums year over year, sometimes they stay the same, they might drop a little, they might go up 50 cents, that’s because we’ve been great at controlling the cost.” But also, this rebate concept is keeping that low.

Some people are saying, “Well, why don’t we move that to the point of sale, so the patient is actually getting the discount more when they’re paying at the pump, versus what they’re paying with their premium?”

Some people really like that idea because it’s giving the patient an easier way to pay and see that cost-savings over the year, but then others say, “Well if you do that, all you’re doing is now Medicare is going to have a higher premium because you’re not putting that cost savings at the end.”

What do you think of this kind of policy where a patient might get the savings, kind of at the front end when they’re at the pharmacy, versus the end in the premium, do you see one of those really working out better for a patient?

Christy M. Gamble, JD, DrPH, MPH: It’s difficult because, like I said before, you have 2 patient populations. Those who can afford [drugs] when they go to the pharmacy, and they want to have a lower-cost at the pharmacy, versus those who [say] “I would [rather] just pay up front this premium.”

We’ve been walking a thin line on which side to advocate on, and we really would like to find a system in an ideal world, where we can take patients as they are. Kind of like a case by case type of view when it comes to the savings.

But for us, we just want to make sure that the cost of these drugs [is] lower, so then you don’t have to come up with these innovative systems to make sure the patient can see a lower cost, either at the pharmacy or in their premiums. I think that’s where we stand right now, is just by saying, “Okay, we need to advocate for these costs to be lower, period,” and then we won’t really have to have these conversations in the end.