Part B to Part D and Other Questions: How CMS’s Plans Could Affect Biosimilars

For 2019, the Trump administration has proposed transferring some products reimbursed by Medicare part B to part D coverage. Additionally, it will allow Medicare Advantage firms, which manage a small but significant percentage of Medicare beneficiaries’ care, to negotiate prices and utilize some pharmacy benefit tools to control costs.

Some of these tactics are a bit late to the party, as commercial insurers and health plans have been employing them for years. To the extent that an injectable treatment can be managed through the pharmacy benefit rather than the medical benefit, the drug can be easily subjected to prior authorization, step therapy, quantity limits, and other tools routinely used.

part b to part d coverageFor the few available biologics and their corresponding biosimilars, these infusions are covered in general on the medical benefit today. Infliximab, filgrastim, and pegfilgrastim are still subject widely to buy-and-bill scenarios. Yet, Neulasta® (pegfilgrastim) is already covered under a medical specialty benefit (fifth tier) for beneficiaries of two sample Medicare Advantage plans (HumanaChoice and Aetna Medicare Choice). In both of these plans, Neulasta is subject to prior authorization requirements. UnitedHealthcare covers it under the medical benefit, generally under its highest copayment or cost sharing tier. In contrast, Zarxio® is on the preferred or second tier for United’s Advantage 3-tier and Small Group plans, also under the medical benefit.

These agents, administered via office- or clinic-based infusions, may also be available through specific distribution channels, like specialty pharmacy. In contrast, self-administered agents like adalimumab may be distributed to patients through specialty pharmacies only, which are part of the managed care machinery.

Insulin is still considered a “transitional drug.” Like adalimumab, it is self-administered. However, it is already covered by Medicare under the part D benefit, at least when used outside of an insulin pump. Therefore, part D providers, like commercial plans, have preferred and nonpreferred insulin products, negotiate for pricing, and may use other pharmacy benefit tools.

The Administration has not yet announced which drugs it will from part B to part D. It is unlikely though that the Centers for Medicare and Medicaid Services will jump beyond the experience of commercial plans and insurers. Until other biosimilars are made available for prescription, the latest CMS attempt to control costs may not directly affect biosimilar manufacturers.

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