In May, the Trump Administration unveiled its drug pricing blueprint and is now seeking public comments.  We would like to share our submitted comments to the blueprint, which focus on Medicaid, and encourage you to submit your own comments by the July 16 deadline.

Prescription drugs are essential for the health of tens of millions of low-income children enrolled in Medicaid, including not only routine care but also treatment and maintenance for chronic conditions such as asthma or attention deficit hyperactivity disorder, illnesses like childhood cancers and serious behavioral health issues, and rarer conditions such as cystic fibrosis, Gaucher’s disease and spinal muscular atrophy.  

Key points from our comments:

• The Medicaid Drug Rebate Program is highly effective.  Enacted in 1990, the Medicaid Drug Rebate Program was intended to make prescription drugs much more affordable for state Medicaid programs by ensuring that Medicaid gets among the largest discounts, and thus among the lowest effective prices, available to any payer.  As we explain in our comments, the Medicaid Drug Rebate Program is highly successful, producing far larger rebates than in Medicare Part D and in private insurance. It thus significantly lowers Medicaid prescription drug costs while ensuring access to needed drugs for low-income children and families as well as people with disabilities and other Medicaid beneficiaries.  As a result, the priority should be to build on and strengthen the successful Rebate Program. 
• Improving the Medicaid Drug Rebate Program would help state Medicaid programs better address rising drug prices and spending.  We recommend a number of sound improvements to the Medicaid Drug Rebate Program, including federal policy changes to discourage manufacturers from instituting excessive launch prices or annual price increases and to ensure better manufacturer compliance with rebate requirements. 
• Extending the Medicaid Drug Rebate Program to other federal health programs would lower costs.  Because the Rebate Program is so effective, we recommend extending Medicaid rebates to separate state CHIP programs and to Medicare Part D to substantially lower prescription drug costs in those programs. 
• Misleading claims about the Medicaid Drug Rebate Program do not withstand scrutiny.  In our comments, we refute the blueprint’s efforts to blame the Medicaid Drug Rebate Program, including rebate improvements included in the Affordable Care Act, for overall rising drug prices and spending.  We explain how these misleading claims are being used to justify damaging proposals to weaken or undermine the Rebate Program, which would sharply increase state Medicaid drug costs and place beneficiary access to needed drugs in serious jeopardy.