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Association Urges CMS to Finalize Withdrawal of MFN Drug Model

In response to a proposed rule, America’s Essential Hospitals urged CMS to finalize withdrawal of the Trump administration’s Most Favored Nation (MFN) Model.

The Centers for Medicare & Medicaid Services (CMS) proposed to rescind the November 2020 interim final rule with comment and remove the related regulatory text due to litigation halting implementation of the MFN Model and stakeholder comments opposing the model start date. The 2020 interim rule created a seven-year model phasing in a reduced payment rate for 50 Medicare Part B drugs over four years and then paying Medicare providers the fully reduced rate for the remaining years of the model.

In comments to the administration, the association urged CMS to finalize its proposal to withdraw the November 2020 interim rule, citing procedural deficiencies, ongoing legal challenges, and significant reduction in provider payment rates. America’s Essential Hospitals noted that if CMS proceeds with implementation, the reimbursement consequences on providers and the effects on patient access to affordable drugs would be especially pronounced as hospitals respond to the continued threat of COVID-19. Further, the association explained the rule would disrupt existing drug distribution and reimbursement practices, with inevitable implications for the 340B Drug Pricing Program and patient access to lifesaving drugs.

Contact Senior Director of Policy Erin O’Malley at or 202.585.0127 with questions.


About the Author

Abigail Painchaud is a policy associate at America's Essential Hospitals.

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