Infusion Providers Alliance
The Infusion Providers Alliance is the leading voice for in-office and freestanding ambulatory facility providers of drug infusion services. Alliance members are committed to preserving the integrity of the provider-patient relationship in a manner that delivers exceptional care to patients at a value to the health care system.
Our members have facilities located in communities across the nation, each of which offers a more convenient, more efficient and less expensive alternative for patients than receiving their infusions in the hospital setting. These facilities serve as critical access points of care for patients and save tremendous dollars for commercial and government payers alike while also lowering out of pocket costs for beneficiaries.
The Infusion Providers Alliance mission is to serve as a thought leader and to educate on issues critical to safeguarding, supporting, and strengthening provider directed, patient-focused access to in-office and freestanding ambulatory facility infusion services.
Efforts to Upend “Buy and Bill” Model May Decrease Patient Access and Increase Costs
The Infusion Providers Alliance believes that recent administrative efforts to replace the “buy-and-bill” distribution services in order to implement an international pricing scheme will impair patient access to critical medications for patients with chronic conditions and place additional burden on the specialist provider community, many of whom have already suffered mightily due to the COVID-19 pandemic and resulting impact on their practice.
International Pricing Index
In 2018, CMMI issued an Advanced Notice of Proposed Rulemaking (ANPRM) that would establish a new Part B pricing model based on an International Pricing Index model, under which the buy-and-bill distribution system would be eliminated for half of the country. The purpose of the model is to reduce U.S. prices for Part B drugs based on an international pricing index. However, the model would also upend the current, reliable “buy-and-bill” distribution system and instead rely on untested new vendors to provide these critical drugs.
The ANPRM suggests contracting with group purchasing organizations, pharmacy benefit managers and distributors; however, to date, these groups have not shown much interest in taking this risk. These new vendors must also satisfy significant state and federal compliance regulations and then establish new distribution channels in a very tight timeframe.
Policymakers have questioned the value of “middlemen” in the delivery of Part D drugs, where much of the negotiated savings are being siphoned off to pharmaceutical benefit managers. Inserting new middlemen in Part B seems counterintuitive as it would benefit these same organizations. It’s not clear that this would actually save costs, and would move the drug revenue, which many community providers rely on to keep their practices solvent, to PBMs and other middlemen.
Lastly, this concept of a new supply chain as part of IPI adds a layer of cost to the provider community in the form of distribution fees that do not exist today with traditional wholesaler relationships. This additional expense would turn therapy administration from a low margin business to a money losing one, thereby causing providers to leave the market entirely, driving care back to most expensive setting, the hospital outpatient department, and creating patient access issues as a result.
From 2006 to 2008, CMS experimented with a vendor-based distribution system under the “Competitive Acquisition Program.” That program failed for many of the reasons mentioned above and ultimately, only one vendor participated in the “competitive” program before it was ultimately terminated.
Most Favored Nation
In July 2020, President Trump announced an executive order for Part B drugs under which Medicare would pay no more than the most-favored nation (MFN) price of other countries. While the details of this proposal have not been released, we hope that such a program would not rely on a vendor model as the IPI proposal did and will not abandon the well-tested buy-and-bill distribution system.
As discussed above, the Infusion Providers Alliance opposes changes to the “buy-and-bill” model that puts patients at risk by unnecessarily increasing the complexity of the supply chain, creating problems with timely access and drug wastage due to changes in therapy regimen and potentially polluting the chain of custody of individual medications for patients.