The Infusion Providers Alliance was proud to join over 40 patient and provider organizations representing the Underwater Biosimilars Coalition in recent letters to Congress and the Federal Trade Commission (FTC) outlining the urgent need to address dynamics negatively impacting patient access to biosimilars and providers’ ability to continue to administer these products.

In our letters, we call for the following legislative actions:

  • Amend Section 1847A to extend the Secretary’s authority to use wholesale acquisition cost (WAC) + 3% until ASP reaches sustainable levels, as determined by the Secretary.
  • Amend Section 1847A(c)(3) to remove from ASP calculations the rebates negotiated between PBMs and drug manufacturers.
  • Call for CMS to either withdraw the 2018 memorandum “Prior Authorization and Step Therapy for Part B Drugs in Medicare Advantage,” or at a minimum, revise the step therapy memo to clarify that beneficiaries should have access to an alternative biosimilar or reference product when the step therapy-preferred biosimilar is not financially viable for physicians to administer.

Our letter to Congress can be viewed here and our letter to the FTC can be viewed here. This follows recommendations we provided to the House Ways & Means Subcommittee on Health for their recent hearing “Lowering Costs for Patients: The Health of the Biosimilar Market” which can be viewed here.