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

West Health’s comment letter addresses CMS’ proposal to include the pharmacy portion of Direct and Indirect Remuneration in the definition of negotiated price for purposes of calculating beneficiary cost-sharing in the Medicare Part D program. West Health shares CMS’ goal of reducing beneficiary cost-sharing and better spreading the net cost of drugs across premiums, the true goal of insurance.