Comments: Part D Rebate Safe Harbor

The Medicare Rights Center (Medicare Rights) appreciates the opportunity to comment on the on the proposed changes to the Safe Harbor Protection for Rebates Involving Prescription Pharmaceuticals and other proposals in OIG-0936-P. Medicare Rights is a national, nonprofit organization that works to ensure access to affordable health care for older adults and people with disabilities through counseling and advocacy, educational programs, and public policy initiatives. Medicare Rights provides services and resources to three million people with Medicare, family caregivers, and professionals each year.

While we are encouraged by the Department of Health and Human Services’ (HHS) efforts to improve transparency within the Part D drug pricing system, we are disappointed that this proposed rule has few guarantees when it comes to lowering high drug prices or beneficiary out-of-pocket costs and leaves open significant questions about its efficacy and impacts.

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