If the Trump administration gets its way, Medicare Part D plan sponsors may at some point be on the hook for a greater share of costs once beneficiaries reach the catastrophic phase of coverage for prescription drugs. While America's Health Insurance Plans (AHIP) is opposed to the idea, experts tell AIS Health that the time may be ripe for such a change.
Beneficiaries enter the catastrophic coverage phase when, as of 2018, their "true out-of-pocket costs" exceed $5,000. Once in that phase, beneficiaries pay no more than 5% of the total cost for their drugs, while the federal government pays 80% and the Part D plan pays 15%.
In its fiscal year 2019 budget proposal, the Trump administration suggests increasing plans' share of costs for catastrophic coverage from 15% to 80% and shifting Medicare's share from 80% to 20%. More recently, CMS Administrator Seema Verma said during an Oct. 18 event that the change is one area in which Part D could be "updated and modernized."
Sean Creighton, a vice president in Avalere Health's policy practice, says the change is probably needed because health plans will soon bear very little risk in the upper end of the Part D benefit.
AHIP, however, says it "strongly disagrees with the basic premise of this proposal — that incentives alone will produce such cost reductions." It argues that "plans are already fully incentivized to negotiate vigorously for lower costs" and "drug companies are incentivized to provide price concessions only when leverage exists."
Creighton says it is possible that shifting more risk to plans could result in higher premiums. But as long as the beneficiary cost-sharing in the catastrophic phase remains the same, the proposed policy change is likely to be "sort of invisible" to members, he adds.
On the other hand, increasing plans' risk will likely cause them to step up some of their price-negotiation practices, such as excluding drugs from formularies, changing tier placement of drugs, and using prior authorization and step therapy. "So it may lead to a situation where access to particular drugs may become more restricted as the plans seek to contain costs," Creighton says.