My recent op-ed on the new Independent Payment Advisory Board (IPAB) generated a lot of comments – and a lot of corrections. And so, in the spirit of transparency and disclosure and (most of all) thanks, here are some important emendations
1. In the article’s fourth paragraph, the last sentence reads, "And the IPAB's policy recommendation automatically will be institute unless Congress overrides them." Technically, it will be implemented automatically unless Congress comes up with its own proposal that meets the same spending cut targets. Congress can also (with 3/5 majority in both houses) pass a resolution rejecting the IPAB proposal, but that can be vetoed by the President and would then be subject to a 2/3 override. I oversimplified. Mea culpa.
2. Sixth paragraph, second sentence reads, "For one, it doesn't have any authority over the biggest cost-drivers in Medicare." I stand corrected. IPAB cannot make recommendations (before 2019) that would "reduce payment rates" to Medicare Part A providers or Part B suppliers. However, IPAB could nevertheless make recommendations with respect to those entities that would have the effect of implementing policies that would be viewed as unfavorable or harmful by those entities (or beneficiaries that rely on Parts A and B.) For example, IPAB could utilize the LCA policy for Part B drugs, establish a Part B national formulary, etc.
3. Ninth paragraph, first sentence reads, "Yet the IPAB has no power over Part A or Part B." While the IPAB cannot make recommendations to cut provider payments in Part A or B before 2019, but that does not mean they have no power over providers in Part A and B and in fact that there are lots of recommendations they could come up with that impacts these providers without cutting their payment.
4. Eleventh paragraph, first sentence, "The IPAB can make drastic changes to Medicare plans, including raising premiums, cutting benefits, and restricting eligibility requirements." Let me clarify. There is a prohibition on recommendations that would increase Medicare beneficiary cost-sharing (including deductibles, coinsurance and copayments) or otherwise restrict benefits or modify eligibility criteria – but the prohibition on raising premiums does not apply to Part D - but these other prohibitions do (rationing, cutting benefits and restricting eligibility.
As George Bernard Shaw wrote, “A life spent making mistakes is not only more honorable, but more useful than a life spent doing nothing."
And many thanks to all you drugwonks out there for the smart and savvy corrections. The devil is in the details.