Agency Information Collection Activities; Proposed Collection; Comment Request; FTC File No. P-125402 #00004

Submission Number:
Kris Alman
Initiative Name:
Agency Information Collection Activities; Proposed Collection; Comment Request; FTC File No. P-125402
This comment is an addendum to one I made on 11/30/2015, with tracking number 00002. The FTC provides information for individuals filing for bankruptcy. The FTC is also the watchdog of consumer privacy and data security. Please help prevent bankruptcies and enforce consumer privacy by clamping down on governmental contractors that perform big data analytics and have inherent conflicts of interest. Medical expenses are still the number one cause of personal bankruptcy. Milliman Inc. writes "A combination of forces is creating the perfect pharmaceutical storm." Premiums and out-of-pocket expenses for a family of four under an employer-sponsored PPO plan rose to $24,671. Since 2010, employers are also paying a smaller percentage of the the total cost of family coverage. Milliman purchases health care data and consults with: pharmacy benefit managers hospitals (a fascinating video on captive insurance programs) health insurance plans, including for rate reviews in Oregon pharmaceutical companies Milliman's fiduciary responsibility is with their clients, not individuals. To assure that insurance companies are actuarially sound, expensive drugs are tiered and unaffordable for many Americans. This past week, Senators Wyden and Grassley held a press release to announce findings from a Senate Finance Committee investigation into the pricing of Sovaldi. Gilead DID NOT base their pricing on research and development costs. Their strategy was to outmaneuver potential competitors to ensure its drugs had the greatest share of the market, for the highest price, and for the longest period of time. Gilead consulted IMS Heath, a health data aggregator like Milliman, for pricing. IMS suggested $80--90K pricing was "acceptable." Governments also risk going broke with the price of pharmaceuticals--especially new biologics. Ezekiel Emanuel, one of the architects of US healthcare reforms, warns the US will struggle to afford the cancer treatments that are now becoming available. President Carter's brain metastases from melanoma have disappeared after he was treated with pembrolizumab, a new class of drugs that block the PD-1 pathway. Last year Merck announced a price tag of $12,500 per patient per month, or $150,000 per year, for the drug. Actuarial and consulting firms (such as Milliman Inc.) and defense contractors (such as General Dynamics Information Technology and 3M) have conflicts of interest when they access protected health information. The FTC should audit third party contractors of governmental big data for conflicts of interests.