Meet
Milena Sullivan

Milena Sullivan advises life sciences clients on the impact of the evolving healthcare policy landscape on their commercial, access, and advocacy priorities.

She focuses on federal health policy in government-regulated markets such as Medicare policy and payment as well as on state policy advocacy and strategy.

Prior to re-joining Avalere, Milena was associate director for Oncology Policy, Market Access, at Bristol-Myers Squibb, where she identified, analyzed, and communicated policy risks and opportunities impacting the oncology business unit, its patients, and customers. She identified competitive opportunities for the company under new CMS payment models and educated internal teams on the evolving public payer landscape. Prior to that, she was a senior manager at Avalere Health, where she supported life science clients on various policy and strategy issues and managed engagements with vaccine companies. She was a project manager, Government Affairs and Public Policy, at Novartis, where she analyzed the impact of the ACA on the vaccine division’s products and customers and led trainings for field-based staff.

Milena has an MA in international policy and practice from The George Washington University and a BA from Miami University of Ohio.

Authored Content


On July 19, the Centers for Medicare & Medicaid Services (CMS) released the CY 2022 OPPS/ASC Proposed Rule, which includes a number of proposals to modify the timing and design of the Center for Medicare & Medicaid Innovation’s forthcoming Radiation Oncology (RO) Model. The design proposals include changes to the set of included modalities and cancer types, reduction of the CMS discount factors applied to the prospective payments, and adoption of an extreme and uncontrollable circumstances policy. Looking ahead, stakeholders should continue to assess the model payment methodology and design in the context of evolving care delivery and practice patterns.

The Patient Centered Outcomes Research Institute (PCORI) recently announced an open comment period for a new set of proposed national priorities to inform its research agenda. Avalere analysis finds that from March 2019 to September 2020, PCORI directed roughly $259 million to comparative effectiveness research (CER) awards with an increasing share of new projects focused on drugs.

Beginning July 1, 2021, average sales price (ASP) calculations for Part B drugs with an additional non-covered self-administered formulation could alter Medicare reimbursement.

As the Oncology Care Model (OCM) approaches its conclusion, stakeholders are anxiously awaiting the details of the Center for Medicare & Medicaid Innovation's (CMMI’s) next oncology episodic payment model, Oncology Care First (OCF).

Join Avalere’s panel of data analytics, market access, and policy experts for a discussion on the potential for federal drug pricing reform in Congress or via administrative action.

A second reconciliation package could include significant drug pricing reforms as a means to pay for permanent coverage expansion and other top priorities.

New Avalere analysis finds that the the Most Favored Nation (MFN) Model would have a significant negative impact on Medicare providers that furnish Part B drugs—especially in oncology and rheumatology—and those in rural areas.

Avalere analysis found that in 2017 and 2018, more than half (56%) of Medicare patients with breast cancer taking a medicine covered by Medicare Part B received a therapy that was not routinely covered by England’s National Health Service (NHS) or its Cancer Drug Fund (CDF).

New Avalere analysis finds that most Medicare fee-for-service (FFS) beneficiaries would not see a substantial reduction in their out-of-pocket (OOP) costs as a result of the Most Favored Nation (MFN) model.

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.

Avalere research was published online in the Journal of Clinical Oncology Clinical Cancer Informatics, showing a considerable drop in cancer screening, diagnosis, and treatment for Medicare beneficiaries as a result of the ongoing COVID-19 pandemic.

Avalere analysis finds that patients with Crohn’s disease who experience a negative outcome when required to step through a plan’s preferred product may face higher upfront out-of-pocket (OOP) costs and could increase costs to payers.

Avalere experts took a closer look at emerging oncology trends, innovative approaches to payment and delivery, and what these changes will mean for patient access.

Tune into our third episode of the Avalere Health Essential Voice: 2020 Election series. In this segment, our experts discuss candidates’ respective approaches to drug pricing policies, and where there is unexpected overlap.

Tune into our third episode of the Avalere Health Essential Voice: 2020 Election series. In this segment, our experts discuss candidates’ respective approaches to drug pricing policies and where there is unexpected overlap.

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.

Yesterday, the Administration released the awaited “Most Favored Nation” Executive Order (EO), which calls for a model that would cap the price Medicare pays for select Part B and D drugs.

The administration’s 4 drug pricing EOs direct agency action across a host of policy areas, including Part D rebates, Part B reimbursement and pricing, 340B drug discounts, and drug importation. Next steps and a timeline for agency action will vary by EO dependent on the specific policies to be advanced or finalized. In the interim, stakeholders should explore outstanding questions and contemplate near- and longer-term policy scenarios.

Avalere continues to find a significant drop in utilization of key physician-administered therapies in 2020 relative to 2019.

In the first episode, Sam Ferguson and Biruk Bekele, consultants in Avalere’s Market Access practice, along with Milena Sullivan, a principal in Avalere’s Policy practice, will discuss how stakeholders are defining value in oncology.

Recent Avalere analysis finds decreases in utilization of oncology and autoimmune treatments across all care settings since the onset of the health crisis.

Oncology practices with a substantial proportion of Oncology Care Model (OCM) episodes in areas with high numbers of COVID-19 cases—such as Connecticut, Louisiana, Massachusetts, New Jersey, New York, and Pennsylvania—may face new challenges in containing total expenditure below target amounts.

Avalere experts discuss how the COVID-19 pandemic has affected oncology care and delivery, and the Oncology Care Model (OCM).

New Avalere analysis finds that practices currently participating in the Oncology Care Model (OCM) would be more likely to receive a Novel Therapy Adjustment (NTA) in the newly proposed Oncology Care First (OCF) Model.

Avalere analysis finds that, despite substantial list price decreases across the PCSK9 inhibitor class, out-of-pocket costs for the majority of 2020 Part D beneficiaries remain significant

Avalere analysis finds that 24 of the top 50 non-vaccine Part B drugs are not on the U.S. Department of Veterans Affairs’ National Formulary.

Avalere analysis of 1,375 Medicare Advantage plans’ 2019 medical benefit drug coverage policies finds that 672—covering approximately 14.3 million lives—apply step therapy to at least 1 of the rheumatoid arthritis biologic drugs covered under Medicare Part B in 2019.

As policymakers explore opportunities to reform Medicare Part B, a tiered average sales price (ASP) add-on payment may be under consideration to align system incentives and curb spending.

Ahead of the American Society of Clinical Oncology's annual meeting, Avalere experts discussed the latest trends in policy, reimbursement, and market access reshaping oncology care.

The costs of ensuring the safety and efficacy of imported drugs and preventing the entry of counterfeit products are among the many factors that must be weighed against any potential savings from a drug importation program.

New Avalere analysis finds that most seniors in Medicare would not see a reduction in their out-of-pocket costs as a result of the International Price Index Model.

Avalere analysis finds that most of the payment reductions from the proposed International Pricing Index Model for Part B drugs would affect oncologists, rheumatologists, and ophthalmologists.

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

New research from Avalere finds that Medicare patients with rheumatoid arthritis (RA) may face higher out-of-pocket costs under a proposal to move Medicare Part B drugs into Part D, absent additional policy change to lower cost sharing in the Part D program.

Under an indication-based formulary design approach, Part D plans will be able to tailor the drugs that are on their formulary by indication.

Beginning in January 2019, Medicare Advantage (MA) plans will have the flexibility to use step-therapy techniques for Part B drugs, according to a CMS memo released on August 7.

A proposed shift of Part B drugs into Part D could affect patient access and increase the burden on providers.

The Department of Health and Human Services is seeking public input on a variety of proposals related to drug costs, providing stakeholders with an unprecedented opportunity to shape the administration's drug pricing policies.

President Trump is expected to announce a drug pricing plan in the coming weeks; signals from the White House indicate potential alignment around several priority policies.

As the discussion intensifies, one of Avalere's experts provides keen observations on what you need to know about this topic.