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Alliance Submits Comments to CMS on Most Favored Nation Interim Final Rule

Published January 27, 2021

Stack of hundred dollar bills next to stack of pill blister packs.

On Tuesday, January 26, 2021, the Alliance for Aging Research submitted a comment letter to the Centers for Medicare & Medicaid Services (CMS) regarding the Most Favored Nation (MFN) Interim Final Rule. In the comments, the Alliance urged the Administration to rescind the rule due to the negative impacts the MFN model would have on patient access to care. According to CMS’s analysis, access to included drugs in the Medicare Part B program would be reduced by nearly 20 percent within three years.

In the comment letter, the Alliance highlighted:

  • How the MFN model would reduce access to current Part B drugs, many of which do not have an analogous substitute, and threaten the financial solvency of many rural and specialty care providers;
  • The MFN’s reliance on use of prices set in other countries, many of which are set through the use of methodologies that discriminate against older adults and individuals with disabilities or chronic conditions and have been banned for use in the Medicare and Medicaid programs;
  • As constructed in the rule, the MFN does not qualify as a “model” that tests a delivery system reform on a limited population. Additionally, the MFN lacks sufficient quality measurement to monitor potential adverse effects of the model on patient care.

In December 2020, the Alliance submitted an amicus brief in federal litigation that resulted in an emergency injunction that prevented the Administration from implementing the MFN model, pending the completion of a formal public review and comment process.

Read the full comment. For more information on the MFN Model, please visit our blog post: Q&A on the Most Favored Nation Drug Pricing Proposal.

Read the full comment. For more information on the MFN Model, please visit our blog post: Q&A on the Most Favored Nation Drug Pricing Proposal.

About the Alliance for Aging Research
The Alliance for Aging Research is the leading nonprofit organization dedicated to accelerating the pace of scientific discoveries and their application to vastly improve the universal human experience of aging and health. The Alliance believes advances in research help people live longer, happier, more productive lives and reduce healthcare costs over the long term. For more than 30 years, the Alliance has guided efforts to substantially increase funding and focus for aging at the National Institutes of Health and Food and Drug Administration; built influential coalitions to guide groundbreaking regulatory improvements for age-related diseases; and created award-winning, high-impact educational materials to improve the health and well-being of older adults and their family caregivers. For more information, visit

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