National Council on Disability Letter to Center for Medicaid and Children's Health Insurance Program Services on Oregon's 1115 Demo Waiver Renewal
To:
Re: Oregon Health Plan (OHP) 1115 Demonstration Waiver Application for Renewal
Dear Mr. Tsai:
The
In 2019, NCD released a report on the QALY/1 describing its discriminatory design (placing a lower value on treatments which extend the lives of people with chronic illnesses and disabilities) and its discriminatory impact (in countries where it is regularly used, access to lifesaving and life extending medications is restricted). The report also detailed alternative cost-effectiveness methodologies to the QALY that are not as discriminatory against people with disabilities - important context since the disability community's concerns with the QALY have been misunderstood/2 as being opposed to cost-effectiveness analysis generally, which is inaccurate.
As you know from our
Our recent communications with your staff confirm that CMS is not examining waiver applications or state Medicaid plans for use of this discriminatory metric, and NCD has not been able to ascertain when or whether HHS or CMS changed its policy regarding states' use of the QALY, since it rejected
NCD unequivocally agrees that drug prices need to be lowered, as high drug prices can themselves be a source of health inequity for people with disabilities. However, their lowering should not be based on a pricing methodology that devalues the lives of people with disabilities and has been proven discriminatory in its impact to access to treatment.
NCD appreciates your efforts to address disparities in health equity for the 80 million people receiving health coverage through Medicaid and the
Respectfully,
Chairman
* * *
Footnotes:
(1) https://ncd.gov/sites/default/files/NCD_Quality_Adjusted_Life_Report_508.pdf (
(2) See,
(3) https://ncd.gov/publications/2021/ncd-letter-cms-regarding-state-medicaid-program-use-qaly (
(4) Letter from
(5) https://www.cms.gov/newsroom/press-releases/cms-announces-director-center-medicaid-and-chip-services
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