Drug spending policies had been anticipated to be one of the largest off-sets in the reconciliation bill, however the magnitude of the included drug spending policies has been limited since initial discussions. Upon the release of the preliminary outline of the prescription drug pricing provisions that were to be included in the final bill, CIDSA experts were asked to analyze how the outline of inflation rebates would impact prices. While the full text has been released in the time since this survey began, experts were asked to limit their analysis to the initial outline.
The preliminary drug pricing provisions that pertained to inflation rebates were particularly limited. The rebates are to be based on 2021 and calculated based on the total drug units sold. The preliminary overview, which the experts were provided with for this survey, did not have any additional information on the implementation timing.
The CIDSA experts agreed that the inflation rebate provision in the reconciliation bill would reduce drug spending; six experts believe the policy would moderately reduce spending, while the other two believed spending would be minimally reduced. Experts were split on the policy’s impact for list and net prices. One expert opined that the list prices would moderately increase, however the other seven agreed they would moderately decrease. Three of the experts opined that the inflation rebates would not affect drug net prices, but the remaining five believed that they would moderately decrease. The panel of experts unanimously agreed that Medicare beneficiaries, privately-insured patients, and large patient groups would see a moderate increase in drug access but were split across the other groups.
The majority of the experts felt that this policy would be a significant advancement of drug spending policy. The experts also highlighted multiple strengths of the inflation rebate, including the ability for it to be implemented, the size of the affected patient population, and the precedent-setting value of the policy.
Only 8 experts were able to participate in this survey.
The expert panel highlighted several policy concerns for policymakers to consider. The most important considerations were the uncertain implications that this policy could have on industry investment, the application of borrowed Medicaid line extension rule, and that it remains unclear if the “inflation” value will change year to year. Another key consideration was that it is unclear if these fines will be extended to the commercial market. Policymakers should also consider the extension of the rule to Part B and the ability for manufacturers to opt to pay the rebate in favor of keeping their prices high or game the reference standard for the inflation calculation.