Letter to CMS on 2023 Policy and Technical Changes to the Medicare Advantage and Medicare Prescription Drug Benefit Programs

March 7, 2022

In the weeks following the release of the proposed rule, CIDSA asked its expert panel to review the proposed rule to determine its potential impact. In this letter, CIDSA summarizes the experts’ findings. CIDSA’s expert panel surveys use a simplified two-stage Delphi survey methodology. In the first stage, experts are presented with a description of the policy and asked to evaluate that policy on standardized metrics; the experts also suggest areas where more information is needed to evaluate the policy. In the second round, the experts once again evaluate the policy on the same metrics, but this time with an anonymous summary of how their peers evaluated the policy in the first round. The experts also score the areas where more information is needed that were suggested in the first round, highlighting questions for policymakers to address. After the second round, CIDSA staff create a visual representation of the second-round scores and summarize the policy in a standard format for publication. For their evaluation of this policy, the CIDSA experts were presented with the excerpts of the proposed rule that applied the new definition of ‘negotiated price’ to all phases of the benefit design, including the coverage gap.

A full copy of the letter can be found here.


CIDSA, the Council for Informed Drug Spending Analysis, is a nonpartisan expert group funded by West Health and focused on bringing a non-pharma perspective to drug spending policy dialogue. Learn more at www.cidsa.org and on Twitter at @CIDSAexperts.

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