2022 Atlanta Board of Trustees Meeting

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

• One study showed that a 25% reduction in the rate of obesity could have led to 7% fewer hospitalizations, 12% fewer ICU admissions, and 12% fewer deaths from COVID-19 by April 2021. 5 CMS can and should update its policy to cover AOMs so that seniors have access to the full continuum of obesity care. • Medicare Part D still prohibits coverage of FDA-approved AOMs under a statutory provision excluding drugs used as “weight loss” or “weight gain” agents. This prohibition was intended to exclude drugs for cosmetic use and predates our understanding of obesity as a chronic disease. However, the Medicare Part D statute does not define “weight loss” and “weight gain” agents and it does not prohibit the treatment of obesity. In fact, the medications are now indicated for “chronic weight management”, not simply for “weight loss”. • CMS’ policy currently interprets the statute to exclude anti-obesity drugs from Part D coverage. CMS adopted this policy in the preamble to a 2008 Part D final rule and can therefore reverse this policy the same way. • CMS took a similar approach when it interpreted the prohibition on agents for weight gain to permit Part D coverage of drugs used to treat AIDS wasting and cachexia. • As our understanding of obesity has evolved, it is important that Medicare no longer exclude AOMs as “weight loss” agents but as important therapies that treat a severe, chronic disease— obesity—and importantly, many of its associated conditions beyond direct weight loss alone, to reduce overall morbidity and mortality. We urge CMS to update its policy in the 2023 Part D Final Rule to ensure coverage for FDA- approved anti-obesity medications. CMS’ policy to exclude AOMs from Part D coverage was adopted in the preamble to a 2008 Part D final rule and can therefore be reversed through similar guidance. We would welcome the opportunity to work with you to ensure that seniors have access to the full continuum of obesity care, including FDA-approved anti-obesity medications. If you have any questions about our comments, please contact me at ethanlazarus@gmail.com. Sincerely,

Ethan Lazarus, MD, FOMA President, Obesity Medicine Association (OMA)

5 Xcenda. The Impact of Obesity on COVID-19 Outcomes of Hospitalizations and Mortality. https://www.xcenda.com/-/media/assets/xcenda/english/content-assets/white- papers-issue-briefs-studies-pdf/xcenda_covid_obesity_update_june2021.pdf