2013 Draft Call Letter: BIO's Comments to CMS

Re: Draft 2013 Call Letter

Dear Mr. Blum and Mr. Spitalnic:

The Biotechnology Industry Organization (BIO) appreciates this opportunity to comment on the Centers for Medicare and Medicaid Services’ (CMS) draft 2013 Call Letter.  BIO represents more than 1,100 biotechnology companies, academic institutions, state biotechnology centers and related organizations across the United States and in more than 30 other nations.  BIO members are involved in the research and development of innovative healthcare, agricultural, industrial and environmental biotechnology products. 

            BIO represents an industry that is devoted to discovering new and innovative vaccines and therapies and ensuring patient access to them.  Many of these vaccines and therapies target conditions that affect people age 65 years and older.  BIO strongly supports CMS’ commitment “to improving the quality of plan choices for beneficiaries who elect to enroll in Medicare Advantage (MA) and prescription drug plans (PDP).”[1]  In our comments below, BIO provides 3 recommendations to further improve the quality of these plans by: (1) using a pneumonia vaccine quality measure in the star ratings set to increase vaccine uptake and improve beneficiary outcomes; (2) expanding access to recommended vaccines through broader provider networks; and (3) reducing the cost-sharing thresholds for Part D plans in order to advance CMS’ goal of improving medication adherence. 

[1] Centers for Medicare & Medicaid Services. “2013 Call Letter.” February 17, 2013. Page 51. Available at: