Personal Contribution

The past week has been the most hectic and frenzied in my short time at UCB. As  a member of the policy team, our job is to analyze and respond to government rules and legislation. The Centers for Medicare and Medicaid Services has recently released a proposed rule with guidance surrounding value based contracting, among other things. Though the rule is only around 35 pages, it is incredibly dense. Part of my tasks have been to read through and analyze sections of the proposed rule and to figure out ways in which the rule would assist UCB and ways in which it would be detrimental to the company. Because of the importance of the rule, different members from the UCB organization are being pulled into the conversation than otherwise would be. As such, there are a lot of new and differing opinions about what is good, what is bad and everything in between. I have been given the opportunity on multiple occasions to voice my opinion, in particular with regard to the analysis of the proposed rule. In addition, I have been conducting background research on prior rules that would help the other UCB members to better understand the context under which the rule is being proposed. The final product of all of our work will be a comment letter sent to CMS, who will (hopefully) incorporate some of the changes we request into the finalized rule. One observation I was able to provide that helped to enhance the final product was an interpretation of a provision called “multiple best pricing.” Multiple best pricing is a type of value based contract that has patients meet certain clinical endpoints in order to achieve a certain price level. When reading through the rule, members of the team all had differing perspectives on the multiple best pricing section. The wording is vague and does not encapsulate a lot of what should be said. However, contextual research and a close reading of the proposed rule, I was better able to enhance the team’s understanding of what the proposed rule is intended to do and what it will actually do.

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