We believe that the EHB regulations governing prescription drugs have generally been working well for patients; however, we propose some areas for improvement and are very concerned that there has been a lack of enforcement of the EHB regulations, an erosion of essential health benefits over the years, and some insurers and pharmacy benefit managers (PBMs) are devising ways to skirt the intent of the EHB law and regulations.
We, the undersigned 71 organizations, on behalf of millions of patients and American consumers who live with complex conditions such as HIV, autoimmune diseases, cancer, diabetes, lupus, hemophilia, mental illness, hepatitis, neurological diseases, and other chronic illnesses, write to comment on the Notice of Benefits and Payment Parameters for 2024 Proposed Rule. The patients we represent appreciate all you are doing to make healthcare more accessible and affordable for beneficiaries. While there are several components of the Proposed Rule that many of us will comment on elsewhere, this letter focuses on those issues that impact access and affordability of prescription drugs.
The HIV+Hepatitis Policy Institute commented on the 2024 Draft Letter to Issuers, praising CMS for planning to conduct adverse tiering review for HIV and hepatitis C medications but expressing disappointment that they continue to allow insurers to collecting copay assistance for drugs that is intended for beneficiaries.
On behalf of patients battling illnesses such as cancer, HIV, diabetes, genetic disorders, and antibiotic-resistant infections, we write to convey our profound opposition to recent actions supported by the Biden administration regarding intellectual property (IP) protections and express our concerns with potential actions that may further erode IP protections that are necessary to produce lifesaving medicines.
HIV+Hep offered comments on the proposed national elimination plan for hepatitis C, asking how the initiative would be funded and authorized, where the initiative would be housed, and why there is a need for the government to purchase medications.