MAPRx Submits Comments to CMS’ Part D Proposed Rule

32 MAPRx Members Urge CMS to Take Care in Reforming Critical Prescription Drug Benefit

Today MAPRx submitted comments on behalf of the Coalition and 32 member organizations to the Centers for Medicare and Medicaid Services’ (CMS) proposed rule entitled Modernizing Part D and Medicare Advantage to Lower Drug Prices and Reduce Out-of-Pocket Expenses which was published in the Federal Register on November 30, 2018.

While MAPRx applauds CMS for looking into ways to improve Medicare’s prescription drug benefit, the Coalition is concerned that many of the provisions in the proposed rule, the Coalition is concerned that the proposed policy changes generally favor health plans instead of focusing on beneficiary protections and overall transparency of information.

In the comment letter, MAPRx focuses specifically on the following issues in the proposed rule:

  • Providing plan flexibility to manage protected classes;
  • Application of step therapy for Part B drugs by Medicare Advantage plans;
  • Explanation of benefits requirements;
  • Changes to the definition of negotiated price; and
  • Pharmacy price concessions in the negotiated price.

Click here to download MAPRx’s comments.


MAPRx is a coalition convened by the Lupus Foundation of America consisting of more than 55 patient, family caregiver, and health professional organizations committed to strengthening and protecting Medicare Part D.