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BIO Submits Comments Re: MA Capitation Rates, Part C and Part D Payment Policies and 2016 Draft Call Letter

<p align="left"><span style="font-size: 1.2em; line-height: 1.7em;">Sean Cavanaugh</span></p>
<p align="left">Deputy Administrator</p>
<p align="left">Director, Center for Medicare</p>
<p align="left">Centers for Medicare &amp; Medicaid Services</p>
<p align="left">7500 Security Boulevard</p>
<p align="left">Baltimore, MD 21244</p>
<p align="left">cc: Jennifer Wuggazer Lazio, F.S.A., M.A.A.A.</p>
<p align="left">Director</p>
<p align="left">Parts C &amp; D Actuarial Group</p>
<p align="left">Office of the Actuary</p>
<p><strong>Re: </strong><strong>Advance Notice of Methodological Changes for Calendar Year (CY) 2016 for Medicare Advantage (MA) Capitation Rates, Part C and Part D Payment Policies and 2016 Call Letter (&ldquo;draft 2016 Call Letter&rdquo;)</strong></p>
<p align="left">Dear Mr. Cavanaugh:</p>
<p align="left">The Biotechnology Industry Organization (BIO) appreciates this opportunity to comment on the Centers for Medicare and Medicaid Services&rsquo; (CMS&rsquo;s) draft 2016 Call Letter.&nbsp;BIO is the world&#39;s largest trade association representing biotechnology companies, academic institutions, state biotechnology centers and related organizations across the United States and in more than 30 other nations. BIO&#39;s members develop medical products and technologies to treat patients afflicted with serious diseases, to delay the onset of these diseases, or to prevent them in the first place. In that way, our members&rsquo; novel therapeutics, vaccines, and diagnostics not only have improved health outcomes, including productivity and quality of life, but also have reduced healthcare expenditures due to fewer physician office visits, hospitalizations, and surgical interventions.</p>
<p>&nbsp;</p>

Sean Cavanaugh

Deputy Administrator

Director, Center for Medicare

Centers for Medicare & Medicaid Services

7500 Security Boulevard

Baltimore, MD 21244

cc: Jennifer Wuggazer Lazio, F.S.A., M.A.A.A.

Director

Parts C & D Actuarial Group

Office of the Actuary

Re: Advance Notice of Methodological Changes for Calendar Year (CY) 2016 for Medicare Advantage (MA) Capitation Rates, Part C and Part D Payment Policies and 2016 Call Letter (“draft 2016 Call Letter”)

Dear Mr. Cavanaugh:

The Biotechnology Industry Organization (BIO) appreciates this opportunity to comment on the Centers for Medicare and Medicaid Services’ (CMS’s) draft 2016 Call Letter. BIO is the world's largest trade association representing biotechnology companies, academic institutions, state biotechnology centers and related organizations across the United States and in more than 30 other nations. BIO's members develop medical products and technologies to treat patients afflicted with serious diseases, to delay the onset of these diseases, or to prevent them in the first place. In that way, our members’ novel therapeutics, vaccines, and diagnostics not only have improved health outcomes, including productivity and quality of life, but also have reduced healthcare expenditures due to fewer physician office visits, hospitalizations, and surgical interventions.

BIO strongly supports CMS’s commitment to improving the quality of the Medicare Advantage and Part D programs.  We consider it especially important to focus on policies that impact access to prescription drugs and vaccines for Medicare beneficiaries in Medicare Advantage and Part D plans. To further improve access to crucial therapies and immunizations for these patients, we urge CMS to consider the following comments, discussed in more detail below.