The Pharmaceutical Research and Manufacturers of America (PhRMA) appreciates the opportunity to comment on your Request for Information (RFI) on Medicare, CMS-4203-NC, published in the Federal Register on August 1, 2022. We applaud the agency’s effort to continue to improve and strengthen Medicare Advantage (MA) and ensure alignment with the Vision for Medicare and the CMS Strategic Pillars, released in April, that prioritize health equity to inure to the benefit of MA beneficiaries.

Access to prescription medications helps patients manage their health conditions, decreases avoidable health care utilization and costs, and reduces mortality. However, marked inequities in access to medicines disproportionately impact underserved populations. This report describes disparities in medication access and adherence, as well as the drivers and populations impacted.

Inequities in health status and outcomes among racial and ethnic groups often are rooted in community-level factors. Recognizing that each community faces unique barriers, PhRMA established the Collaborative Actions to Reach Equity (CAREs) grant program in April 2020. To date, awards have supported research and efforts to advance equity across the country - and round 4 of grantees have been finalized.

As health insurance benefit designs increasingly shift prescription drug costs to patients or impose other barriers to access, the impact disproportionately falls on people of color. This report outlines how many common commercial health insurance benefit design features create barriers to access medicines, why these barriers impact underserved communities and communities of color…

In the United States, nearly one in ten new prescriptions, a total of 55 million, were never picked up at the pharmacy in 2020. However, medicine abandonment does not impact all populations equally. An analysis based on IQVIA data revealed that even with insurance, African American patients are less likely to pick up their medicines at the pharmacy counter than White patients. This can lead to worse health outcomes for these patients and further contribute to existing gaps in health equity.

The Pharmaceutical Research and Manufacturers of America (PhRMA) appreciates the opportunity to comment on the Congressional Social Determinants of Health Caucus Request for Information (RFI), which seeks feedback on challenges and opportunities related to social determinants of health. Consistent with our priority of building a more just, equitable health care system, PhRMA believes that diversity, equity, and inclusion are essential to the discovery of new medicines…

PhRMA appreciates the opportunity to comment on OMB's Request for Information (RFI), “Methods and Leading Practices for Advancing Equity and Support for Underserved Communities Through Government,” which was published in the Federal Register on May 5, 2021.

PhRMA appreciates the opportunity to comment on proposed Medicare FY 2022 Inpatient Psychiatric Facilities Prospective Payment System and Quality Reporting Updates for Fiscal Year Beginning October 1, 2021, specifically in response to the Request for Information on Closing the Health Equity Gap in CMS Quality Programs.

Today, there are more than 800 medicines in development for diseases that disproportionately affect racial and ethnic communities. A new report from PhRMA explores these medicines that target these diseases and conditions, which not only affect these racial and ethnic communities at a higher rate, but are also associated with worse COVID-19 outcomes.

The Pharmaceutical Research and Manufacturers of America (PhRMA) appreciates the opportunity to comment on the NIH’s request for information on approaches to advance racial equity, diversity, and inclusion within all facets of the biomedical research workforce and expand research to eliminate health disparities and foster equity.