10.25.2023 OMA Board Book

7173 S. Havana St #600-130 Centennial, CO 80112 P: 303.770.2526 | F: 303.779.4834 obesitymedicine.org

September 27, 2023

Annete Grant, RPh KS Medicaid Pharmacy Program Manager Sarah Fer�g KS Medicaid Director

Dear Annete,

On behalf of the Obesity Medicine Associa�on (OMA) , an organiza�on of nearly 5,000 expert medical clinicians who treat the chronic and relapsing disease of obesity, we would like to express our apprecia�on to the Kansas Medicaid program for adop�ng many of our suggested changes to its dra� Prior Authoriza�on (PA) criteria surrounding an� - obesity medica�ons (AOMs) . These include changing the nomenclature for the category from weight loss agents to an� - obesity m edica�ons and removing the PA criteria for the generic/lesser expensive AOMs . However, we con�nue to be troubled by the program ’ s remaining PA criteria that will significantly restrict pa�ent access to these powerful tools to treat their disease. We understand the need to have the more expensive GLP1 agonist type AOMs, semaglu�de (Wegovy) and liraglu�de (Saxenda) under a second �er requiring PA but limi�ng access to these medica�ons to only those with ‘ severe obesity ’ with a BMI over 40 or adolescents with BMI > 140% of 95% is problema�c. Pa�ents with a BMI 30 - 39 can have severe disease when they also have any of the 14 co - morbid condi�ons listed in Table 2. Therefore, we would suggest lower BMI thresholds such as a BMI of 30- 35 with a comorbidity or a BMI of 35 or higher without comorbidi�es. It doesn ’ t make sense to wait un�l someone has a BMI of 40 and in poorer health and costlier to the system, to allow them access to the most effec�ve treatments. We also remain concerned over lifestyle modifica�on requirements that require pa�ents to lose >3% of their body weight (or 2% BMI decrease for adolescents) to earn access to these newer medica�ons as there is no evidence base that such a requirement is predic�ve of someone ’ s degree of success with AOMs . Lifestyle changes are recommended for pa�ents with diabetes, hypertension, heart disease , etc but none of these chronic condi�ons require 3 months of a lifestyle modifica�on program to gain access to treatment. In truth, by the �me pa�ents request help from a medical provider to treat their obesity, they have made mul�ple atempts at lifestyle change. Most of them have had success with weight loss but their story usually includes gradual weight recurrence due to the chronic and relapsing nature of obesity, not the pa�ents ’ lack of diligence with diet and exercise. In this vein , we also ques�on other measures which will undoubtedly set up pa�ents to fail such as the unrealis�c and puni�ve weight loss percentages outlined in the renewal criteria that we highlighted in our July 18 th leter. Finally, we are concerned that the u�liza�on and pricing numbers that the program are quo�ng are highly misleading such as the $821 billion to treat 737,000 ten- year - old children throughout 70 years assuming the current monthly wholesale price of $1349 for semaglu�de . T he Medicaid Drug Rebate Program mandates that manufacturers must pay a base rebate equal to a minimum rebate of 23.1 percent of the Average Manufacturer Price (AMP) or the AMP minus the “ best price ” provided to most other purchasers, whichever is greater. Therefore, these kind of assump�ons are irresponsible and are only designed to further bias and s�gma against