"Reference pricing goes hand-in-hand with strong, underlying access requirements linked to network availability, capabilities, composition and performance. It is promising that CMS plans to engage in rulemaking to develop its own standards, but with regard to reference pricing, federal regulators should not put the cart before the horse by allowing reference pricing before network ground rules are set. The agencies also should not remove the limits on annual out-of-pocket costs for patients who use providers not accepting a reference price."  MORE >>