Chuck Rynearson-WI

Document ID: CMS-2008-0056-0037
Document Type: Public Submission
Agency: Centers For Medicare & Medicaid Services
Received Date: July 14 2008, at 12:30 PM Eastern Daylight Time
Date Posted: July 28 2008, at 12:00 AM Eastern Standard Time
Comment Start Date: May 16 2008, at 12:00 AM Eastern Standard Time
Comment Due Date: July 15 2008, at 11:59 PM Eastern Standard Time
Tracking Number: 80673226
View Document:

This is comment on Proposed Rule

Medicare Program; Revisions to the Medicare Advantage and Prescription Drug Benefit Programs

View Comment

When Congress established the Medicare Part D program and when CMS initialy set up the regulations there was a significant effort made to keep this process as a freemarket enterprise. Clearly a certain degree of oversite is required but the success to date of the program can be attributed to Managed Care organizations doing what they do best. My concern with some of the proposed changes is that the ability of Manged Care organizations to do their job and seek out the best most cost effective way of delivering care is being eroded. Specifically, the redefinition of PDE costs in effect, eliminates the current options we have for contracting to allow transparency via disclosure. The best means for contracting with PBM's is still open for debate and I would ask that CMS not restrict our choice in this matter. Please allow the market place to work so Part D can continue to deliver better than projected results.