While we are supportive of the Maryland Prescription Drug Affordability Board (PDAB) goal of improving treatment affordability, we urge PDAB members and staff to address concerns surrounding access to provider-recommended HIV treatments at the individual level and the impact on broader public health goals and provide clarity around the affordability review process to enable meaningful community input.
We support changing the state EHB benchmark plan to one that covers all FDA-approved tests and drugs to treat and prevent HIV, hepatitis B, hepatitis C, and opioid use. It is a timely juncture for states that wish to improve access to testing, treatment, and prevention for HIV and viral hepatitis to consider an update to a more generous EHB benchmark plan. The recently finalized 2025 Notice of Benefit and Payment Parameters has created new opportunities for states to define what comprehensive health insurance should look like and to close gaps in coverage.
Employer-sponsored insurance is the most common form of health insurance in the United States, covering over 60 percent of the population under 65.[1] As we detail below, many employers have begun to create new health insurance barriers that prevent employees and their family members from accessing the medications they need to stay alive and healthy. Our comments focus on certain novel benefit designs that have become more prevalent in recent years among employer-sponsored insurance plans: copay accumulators, copay maximizers, and alternative funding programs, as well as the practice of skirting ACA requirements by designating certain specialty medications as non-Essential Health Benefits.
It is a pleasure to voice our strong support for Senate Bill 354-FN (“relative to insurance cost-sharing calculations”) which would require health insurers and pharmacy benefit managers to include any amount paid by the enrollee or on their behalf in calculating an enrollee’s contribution to cost-sharing requirements. We thank you for holding a hearing on this important issue and ask that you consider and pass the bill.
We appreciate all you are doing to make healthcare more accessible and affordable for beneficiaries, including several proposals contained in the proposed rule. While we support several of them, this letter focuses on those issues that impact access and affordability of prescription drugs.