Federal Trade Commission Staff Comment To the Centers For Medicare and Medicaid Services Regarding the Proposed Rule Entitled "Contract Year 2015 Policy and Technical Changes to the Medicare Advantage and the Medicare Prescription Drug Benefit Programs"

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Staff submitted a comment to CMS, in response to a request for public comments, regarding proposed changes in contracting for Medicare Part D. The comment recommended that CMS reconsider a proposal to implement an “any willing pharmacy” provision, and further examine whether such provisions are likely to benefit Part D beneficiaries and the Part D program. The comment noted that health plans’ ability to construct networks that include some, but not all, providers can be an important tool to enhance competition and lower costs in markets for health care goods and services.