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.
Comments in support of New Hampshire SB 354
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.
Comments on the NBPP proposed rule for 2025
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.
Comments on 2025 draft letter to issuers in the federally-facilitated exchanges
The HIV+Hepatitis Policy Institute submitted comments recommending that the 2025 Draft Letter to Issuers in the Federal-facilitated Exchange include a reminder to issuers that copay assistance must be counted for all but brand name drugs with a generic equivalent, plans be flagged for adverse tiering when all or a majority of drugs to treat a certain condition are on the highest tiers, CMS takes a more proactive role in enforcement action against insurers that violate the law, and CCIIO fully reviews plans for benefit designs that discriminate against certain individuals.
Expanding PrEP access now
In public comments to the President’s Advisory Council on HIV/AIDS, the HIV+Hepatitis Policy Institute suggests ways that the federal government can improve PrEP uptake: 1) having CMS ensure that private insurers comply with ACA $0 cost-sharing requirements, 2) having the CDC’s Division of HIV Prevention dedicate more funding for PrEP, and 3) having HRSA ensure that the community health centers PrEP program works effectively.