A Tale of Two Patients: Who Will the Proposed Safe Harbor Regulation Most Benefit?

Posted by Pranava Goundan on Thu, Apr 11, 2019

Howard Deutsch and Kyle Harpole co-wrote this blog post with Pranava Goundan.

The U.S. Department of Health and Human Services has proposed a new rule for safe harbor protection of drug discounts, effective Jan. 1, 2020. While the rule hasn’t been finalized, it has received more than 25,000 public comments, indicating that the current rebate model likely will be swept out to sea in favor of a model that aims to more directly address beneficiaries’ concerns about rising out-of-pocket costs. The percentage of patients whose out-of-pocket spending exceeds $2,000 nearly doubled between 2011 and 2015. The proposed regulation focuses on curtailing these costs by establishing, among other things, point-of-sale discounts for beneficiaries. We recently wrote about how pharma can prepare for the shifting seas of a new access and reimbursement landscape. In this post, we’ll compare two common Medicare Part D, non-LIS patient populations, diabetes and rheumatoid arthritis, to demonstrate how individual patients’ payment contributions would change under the proposed regulation.


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Transitioning Pharma to Value-Based Payments Will Require More Than Corporate Collaboration

Posted by Paul Darling on Tue, Mar 01, 2016

Healthcare reimbursement in the U.S. is undergoing a fundamental transformation. The Center for Medicare & Medicaid Services has led this transformation, announcing that 50% of all Medicare payments will shift from fee-for-service to alternative payment models by 2018. Pharmaceuticals have been entirely omitted from these plans, as Medicare is legislatively prevented from negotiating drug prices. Hence, manufacturers and private payers are expected to play a dominant role in determining payment models that reimburse pharmaceutical manufactures for value in the form of patient outcomes, rather than the pills, themselves.


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