We strongly support Utah’s “Health Insurance Modifications,” which would require health insurers to accept and count payments made on behalf of patients towards deductibles and out-of-pocket maximums. We thank you for introducing this bill and look forward to its passage by the Judiciary Interim Committee.
These benefit designs, which discourage enrollment by Iowans living with HIV, are plainly discriminatory. We urge the Iowa Insurance Division, which reviews, approves, and regulates Marketplace plans in Iowa, to take immediate action against Medica for offering these substandard plans that violate the ACA and its implementing regulations. We urge you to ensure that these violations are rectified before the new plan year begins.
While we appreciate the many steps that you are taking to make healthcare more accessible and affordable for beneficiaries, the majority of this comment on the Proposed NBPP Rule focuses on the need for CMS and related federal agencies to take the necessary steps to increase access and affordability of prescription drugs that should have been included in the Draft NBPP Rule but were not.
In our comments we reiterate our profound disappointment with CCIIO and state regulators for not enforcing the strong ACA nondiscrimination patient protections, including a prohibition on adverse tiering in drug formularies and the requirement to cover the drugs included in widely accepted treatment guidelines. We also outline a number of recent examples by insurers, including some new ones, that either CCIIO or states are permitting to operate that do not protect the interests of people living with HIV since they market discriminatory benefit plans designs.
As the Oregon legislature considers modifications to SB 844, we write to express our support for proposed legislative recommendations including enhancing transparency around the use of copay accumulators, copay maximizers, and alternative funding programs. In recent years, insurers and their PBMs have implemented harmful policies that shift financial responsibilities for prescription costs to patients by not applying copayment assistance from drug manufacturers and sometimes charitable organizations.