PhRMA also opposes adding more tiers to formularies, saying it would make costs less predictable and lead to higher patient cost-sharing. A group of 71 patient advocacy groups also signed on to a response to the NPBB, led by the HIV+Hepatitis Policy Institute. Though they criticized other aspects of the proposed rule, they wrote in support of the tiering proposal. “Generic drugs should, for the most part, be on the generic tier,” the comments say. “We do not support the option that certain generics, such as those with a higher cost, be on the specialty tier. Reason would conclude that it should be on a lower tier than the brand, but other factors lead to drug tier placement.” The groups appreciate CMS’ steps to address adverse tiering, the comments say, but are “disappointed that there has been a lack of enforcement and actions against insurers and pharmacy benefit managers (PBMs) that discriminate against beneficiaries with chronic health conditions.”
PhRMA, insurers at odds over drug tiering proposal in exchange rule
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