Letter to CMS on 2028 Drug Price Negotiation: Consider the Impact on Medical Research, Patient Outcomes
Published June 26, 2025
Today, the Alliance for Aging Research submitted a comment letter to the Centers for Medicare and Medicaid Services (CMS) regarding the Draft Guidance on the Medicare Drug Price Negotiation Program for 2028. In the letter, the Alliance urges CMS to consider the impact of its policies on medical research and patient outcomes, and to adopt a more transparent and inclusive approach to price negotiation and patient engagement.
The Alliance advocates the importance of protecting beneficiaries from potential abuses of utilization management techniques, stressing that changes to the Medicare Part D program — as passed in the Inflation Reduction Act of 2022 — require concrete measures to prevent these abuses and ensure optimal patient care for older adults.
The letter also warns of expensive and avoidable costs of inclusion of Part B drugs if negotiation is implemented improperly. Emphasizing a lack of transparency in CMS’s methodology for negotiating drug prices, the letter calls for the agency to release information on how MFPs are established. This transparency would encourage relevant data collection and ensure public trust in the negotiation process.
Additionally, the Alliance advocates for methodologies that fairly represent all patient populations and voices concerns about the potential use of discriminatory metrics like Quality Adjusted Life Year (QALY) or Equal Value of Life Years (evLY) in price setting.
Finally, the Alliance urges CMS to consider the impact of its policies on medical research and patient outcomes, advocating for a more transparent and inclusive approach to price negotiation and patient engagement.