In comments on the Centers for Medicare & Medicaid Services' advance notice of proposed rulemaking on the International Pricing Index model for Medicare Part B drugs, AHA commends the agency's willingness to address excessive growth in drug prices, but "given the amount of model specifics still to be determined, the anticipated operational burdens, as well as other logistical concerns, the AHA urges CMS to consider narrowing the scope of the program to a more targeted intervention than that described in the ANPRM." AHA's Dec. 27 comments and concerns focused on the ANPRM's impact on hospitals participating in the 340B Drug Pricing Program; regulatory and operational burden; payment reductions; and model vendors' fees and policies. The AHA noted that its primary concern is the model's interaction with the 340B program and asked CMS to hold 340B hospitals harmless under the model. AHA said it looks forward to working with CMS "to improve the IPI model."

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