In the final hours of the previous Administration’s time in office, the Center for Medicare & Medicaid Innovation (the Innovation Center) (CMMI) announced new changes for CY 2022 to an existing five-year Part D Payment Modernization Model. This model would provide “formulary flexibility” by exempting Part D plans in the Model from some of Part D’s normal formulary coverage requirements, including rules for the six “protected classes” and the two drugs per class requirement. This change would ultimately impact the most vulnerable patients, including those with cancer, mental illness, and HIV in the middle of a global health pandemic. PhRMA is strongly opposed to these last-second changes.
