Families USA Comment on GUARD Drug Pricing Model

Families USA submitted comment on the Centers for Medicare & Medicaid Services (CMS) model GUARD (Guarding U.S. Medicare Against Rising Drug Costs).

Families USA supports the broader efforts to test new payment approaches to reduce the cost of prescription drugs and increase Medicare sustainability, but we have significant concerns that the GUARD model as proposed would increase cost-sharing for Medicare beneficiaries and introduce a layer of administrative complexity which is inconsistent with the stated goals of the model, ultimately undermining access to Part D benefits. As a result, we oppose the proposed model in its current form and offer comments which highlight and address our major concerns.