HFMA Comments on Most Favored Nation (MFN) Model Interim Final Rule

In a comment letter to CMS regarding the Most Favored Nation (MFN) Model Interim Final Rule (IFC), published in the Federal Register on November 27, 2020, HFMA noted that its members request that CMS withdraw the MFN Model immediately and begin a process of working with impacted stakeholders to develop and propose a payment model pilot that will actually address this root cause of unchecked inflation in  drug costs – manufacturer prices. HFMA believes any model that addresses manufacturer prices should not just address separately payable Part B drugs, but all drugs covered by Medicare Parts A, B, C and D. The letter addresses key concerns of HFMA’s members in detail. Specific concerns about the MFN Model IFC addressed in the letter include its:

  • Adverse Impact to Medicare Beneficiaries and Providers Who Administer High Volumes of MFN Covered Drugs
  • Misappropriation of the Center for Medicare & Medicaid Innovation’s (CMMI’s) Writ Subvert Congress’s Authority and Implement a National Payment Cut for Selected Separately Payable Par B Drugs
  • Failure to Give Stakeholders an Adequate Notice and Opportunity to Comment as Required by the Administrative Procedures Act (APA)
  • Scope and Timing

Download the comment letter