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The CMS Cost-Control Lab Is Actually Increasing Health Spending. Oof

Plus a must-read paper on what the IRA will do to formularies, and how that will impact patients

This Congressional Budget Office report on the Center for Medicare & Medicaid Innovation makes for fascinating reading. As background, CMMI was created as part of the Affordable Care Act, designed to be a laboratory for testing ways to bring health care costs down.

But that didn’t happen, as the CBO documents. CMMI actually drove net spending higher: the savings that CMMI pilots generated ($2.6 billion) were dwarfed by the spending on those programs ($7.9 billion). CBO suggested that the pattern is likely to persist going forward.

As with any discussion of health spending, caveats and explanations abound. But the most powerful way to think about cost-savings in general is that every dollar of savings to the health system is a dollar that comes out of someone’s pocket, somewhere along the chain. No one wants to lose that dollar, and CMMI has not been able to overcome that basic financial reality.

the arc

The Inflation Reduction Act is going to change the way that drugs are managed by insurance plans and PBMs. This isn’t really a statement of opinion. The benefit design for seniors in Medicare Part D is going to be fundamentally redesigned, and that’s going to fundamentally change the incentives for insurance companies.

So it’s worthwhile to start thinking about how those different incentives will show up for patients, which makes this Hayden Consulting Group white paper a must-read.

In essence, it asks the question: in a Medicare program where insurance plans are responsible for a greater share of drug costs, how will those plans change their approach to limit risk and boost savings?

Here’s what Hayden suggests will happen. Plans will consider:

Adding UM restrictions on covered medicines (e.g., requiring prior authorization, fail first, or step therapy);
and/or; Placing medicines that do not offer large discounts on higher tiers that require higher patient cost sharing; and/or;
Excluding more medicines from formularies or increasing UM (within bounds of the coverage requirements for protected classes and medicines with MFPs).

These possible actions by plans due to the IRA will result in more narrow formularies and reduced coverage and access to therapeutic options for patients.

This is one of the more important untold stories of the IRA, and Hayden presents a fairly dark -- but well-reasoned -- picture of what will happen when all of the pieces of the law click into place. (The Hayden paper also looks at why having lots of available therapeutic alternatives is important, and that’s a worthwhile reference, too.)

Others have presented sunnier, if more Pollyannaish, ways to think about the same set of circumstances, in which price-controlled medicines drive down prices across entire therapeutic areas.

Regardless of whether you’re wearing your rose-colored glasses, there seems to be a quiet consensus that payers are going to play all kinds of formulary games that are almost certainly going to boomerang back to patients and providers.

quick turns

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