Meet
Miryam Frieder

Senior Advisor

Miryam Frieder leads Avalere’s Policy practice, advising a wide range of clients on Medicare Part D and the drug pricing policy environment.

Recently, Miryam has helped drug manufacturers, pharmacies, and pharmacy benefit managers plan for the potential impacts of expected drug pricing reforms and other major health policy proposals. She has overseen the development of a model to gauge how different policies may affect investment in research and development and is working with multiple manufacturers to anticipate CMS action and prepare regulatory strategies associated with the Inflation Reduction Act.

Before joining Avalere, Miryam worked at The Lewin Group, where she provided strategic consulting to health plans, hospitals, pharmaceutical manufacturers, and pharmacy benefit managers.

Miryam holds an MBA from Columbia Business School and a Master of Public Health in health policy from the Mailman School of Public Health at Columbia University. She graduated Phi Beta Kappa with a BA in molecular biology and biochemistry from Wesleyan University.

Authored Content


An Avalere analysis assessing differences in Medicare expenditures and utilization across 4 models provides a new perspective on the evolving physician affiliation model landscape.

Ashley Flint brings 12 years of policy experience in the life sciences industry, with deep knowledge of prescription drug pricing, access, and reimbursement.

Avalere experts discussed how IRA’s Part D redesign may affect plan behavior in Plan Year 2025 and how manufacturers should approach contracting and market access.

Emily Lobelo, who has served for 15 years at the CDC, brings extensive knowledge of the vaccine landscape to Avalere’s policy team.

As a strategic advisor to the Policy Practice, Lisa Joldersma adds deep expertise in Medicare, commercial and employer-based insurance, and state policy issues.

The use of DIR in Medicare Part D has increased in recent years, and both the IRA and CMS rulemaking are likely to influence DIR dynamics in the future.

The veteran health policy professional brings expertise in coverage, access, and reimbursement and experience working with providers, plans, and manufacturers.

Implementation of the OOP smoothing program will require additional clarity from the Centers for Medicare & Medicaid Services (CMS) on elements that will affect beneficiary experience, access, and overall sustainability of the smoothing program.

Veteran health policy professional brings deep expertise in value assessment, pharmaceutical value-based pricing, and payment reform.

Analysis of updated Senate drug pricing legislation shows Medicare negotiation could reduce manufacturer revenues by $165 billion in Part D and $290 billion in Part B from 2026 to 2032.

An updated Avalere analysis finds that under the changes to the negotiation policy included in the revised version of the Senate reconciliation package, the 100 Medicare Part B and D drugs that are likely to be selected for government negotiation from 2026–2031 represent almost half (45%) of all Part B and D drug spending in 2020.

New Avalere analysis finds that 3 proposals to redesign the Part D benefit would lead to larger increases in mandatory manufacturer discounts on brand drugs within the Part D “6 protected classes” compared to brand Part D drugs overall. Mandatory manufacturer discounts within the protected classes would increase by 661%, 301%, and 409% across the 3 proposals evaluated, compared to 153%, 63%, and 64% for Part D drugs overall.

They bring nearly 40 years combined healthcare experience to the firm, with expertise in the health insurance sector.

Earlier today, the Trump Administration released long-anticipated drug pricing reforms, including rules related to a Most Favored Nation (MFN) approach for drugs administered by providers in Medicare and rebate reform for the Medicare Part D program. Both rules represent fundamental shifts in our current system and have significant implications for manufacturers, health plans, pharmacies, providers, and patients.

The Coronavirus Aid, Relief, and Economic Security (CARES) Act appropriated $100 billion for the Public Health and Social Services Emergency Fund—known as the Provider Relief Fund (PRF)—and subsequent legislation appropriated an additional $75 billion through the Paycheck Protection Program and Health Care Enhancement Act.

On September 13, the Trump Administration released the much-anticipated “Most Favored Nation” (MFN) Executive Order (EO), calling for models that would cap the price Medicare pays for select Part B and D drugs. The President’s EO underscores the administration’s continued focus on reducing prescription drug price disparities between the US and other developed countries.

Tune into another episode of Start Your Day with Avalere. In this segment, vaccines experts Richard Hughes IV and Dr. Angela Shen discuss the issue of vaccine hesitancy and the gaps in infrastructure and policy that affect adult vaccine uptake.

Tune into another episode of Start Your Day with Avalere. In this segment, experts from our vaccines team discuss challenges within the vaccines marketplace and highlight the efforts currently underway to improve access and uptake among adults.

On July 24, the administration released 3 executive orders (EO) and announced the planned publication of a fourth EO, all focused on prescription drug pricing. The EOs reflect a combination of familiar policy goals (e.g., rebate reform, importation, international pricing) and a new 340B initiative, and in combination could have substantial implications for healthcare stakeholders and pharmaceutical markets if implemented.

He brings healthcare tech, data, advocacy, and strategy experience to the firm.

Avalere analysis of Medicare fee-for-service (FFS) hospital stay claims with associated COVID-19 diagnoses finds that total US healthcare system costs for hospitalizations due to COVID-19 could range from $9.6B to $16.9B in 2020.

New Avalere analysis finds that Medicare Part D patients taking brand prostate cancer drugs enrolled in Employer Group Waiver Plans (EGWPs) have more prescriptions in the coverage gap than patients in non-employer plans.

Prescription drugs are dispensed to patients through a complex supply chain that involves a broad array of entities, contract arrangements, and payments. The following diagram outlines how a typical prescription drug may flow through the drug supply chain.

Avalere experts examined evolving stakeholder-specific considerations for reshaping how patients with autoimmune conditions receive care during and after the COVID-19 pandemic.

As the COVID-19 pandemic unfolds, stakeholders across the healthcare system are facing new realities that will affect the environment in which drugs are commercialized and accessed.

Just because we can’t meet at sPCMA doesn’t mean we can’t discuss what’s next for Medicare Part D.

Employer Group Waiver Plans (EGWPs) have lower out-of-pocket (OOP) costs for multiple sclerosis (MS) drugs than beneficiaries enrolled in other types of Part D plans.

Implementation of a preferred specialty tier could have various impacts on Part D plans’ formulary and benefit designs and could affect manufacturer contracting strategies.

On January 29, Richard Hughes published a piece on the Health Affairs blog discussing the presidential candidates’ opportunities to incorporate preventative services into their healthcare policy platforms.

As policymakers consider reforms to the Part D benefit to address rising out-of-pocket (OOP) costs by adding a maximum OOP cap, an Avalere analysis examines the types of beneficiaries mostly likely to be helped by such a policy.

Avalere analysis finds that tying Medicare Part D manufacturer discounts to utilization in the catastrophic phase instead of in the coverage gap would have differential impacts by disease area.

Dr. Angela Shen Joins the Firm

On April 5, CMS issued guidance announcing a voluntary, 2-year demonstration that would modify the Part D risk corridors if the proposed rule to revise the Anti-Kickback Statute safe harbors is effective for 2020.

The interaction of recently announced drug pricing reforms will have differential implications for stakeholders.

The swift proposed implementation timeline will require stakeholders to evaluate quickly operational requirements, behavioral responses, cross-program implications, and impact on contractual arrangements.

Yesterday, the Department of Health and Human Services Office of Inspector General released a proposed rule redefining the current safe harbor for pharmaceutical manufacturer discounts and rebates to entities like health plans and pharmacy benefit managers (PBMs).

New Avalere analysis finds that beneficiaries enrolled in Employer Group Waiver Plans (EGWPs) have lower out-of-pocket (OOP) costs for select drugs than beneficiaries enrolled in other types of Part D plans.

Avalere experts examine the current drug pricing policy landscape and what potential changes stakeholders should prepare for.

Transformative medicines, like gene and cell therapies, are beginning to be approved in the US, and more are expected to come.

On September 22, California became the sixth state to limit or ban short-term limited-duration insurance (STLDI) plans.

Yesterday, the Centers for Medicare & Medicaid Services (CMS) released Part II of the Advance Notice and Call Letter (ANCL), describing the Agency's proposed 2019 payment policies and other policy updates for the upcoming plan year for Medicare Advantage (MA) and Part D plans.

The Centers for Medicare & Medicaid Services (CMS) just released the annual Landscape Files containing data on plan participation, beneficiary premiums, and benefit designs for the 2018 Part D — Medicare's prescription drug benefit — and Medicare Advantage (MA) markets.

On July 31, the Centers for Medicare & Medicaid Services (CMS) announced that the base Part D premium will be $35 for 2018.

According to a new Avalere analysis of data from the Centers for Medicare & Medicaid Services (CMS), premiums for stand-alone prescription drug plans (PDPs) will increase and the number of PDPs available in 2017 will decrease. Conversely, the Medicare Advantage market appears strong as 8 in 10 beneficiaries have access to MA plans that offer prescription drug benefits with a zero premium.

The Centers for Medicare & Medicaid Services (CMS) just released the annual Landscape Files containing data on plan participation, beneficiary premiums, and benefit designs for the 2017 Part D and Medicare Advantage (MA) markets. Avalere offers the following observations on key trends in the MA and Part D programs that are likely to influence the 2017 market.

Avalere recently analyzed two different Part D policy proposals outlined in The Medicare Payment Advisory Commission (MedPAC) June 2016 report to Congress.

Cost-sharing changes could increase costs for many beneficiaries.

Avalere Experts Estimate MedPAC Proposal to Change Calculation of Part D Enrollees' True Out-of-Pocket Spending Would Increase Beneficiary Costs by $4.1 Billion Between 2017-2020

Percentage of drugs in Part D plans that require coinsurance increased significantly since 2014. Medicare Advantage plans require coinsurance far less often than Part D plans.

The CalPERS Basic Plan Drug List, which is the formulary for all California public employees, includes 222 brand drugs and 287 generic drugs. In contrast, drug coverage in the Veterans Administration (VA) and Medi-Cal (California's Medicaid program) is far more limited than the CalPERS drug list.

Overall, implementation of the duals demonstrations is slower than expected and states continue to delay.