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.
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, and neurological conditions write to comment on the Proposed Rulemaking for ACA Section 1557 Nondiscrimination in Health Programs and Activities. As detailed below, we are extremely pleased that you have taken meaningful steps to improve upon current regulations to ensure that people are not discriminated against in healthcare. In several instances, you have proposed to restore protections that had been included in the past but later withdrawn. In other instances, you have provided further clarity on what constitutes discrimination. In any instance, we emphasize that the law and whatever is finalized in regulation must be strictly enforced.
HIV+Hep strongly supports the “Copay Accumulator Amendment Act of 2021” (Bill 24-0557) introduced by Chairman Gray and four councilmembers. It simply requires that the copay assistance beneficiaries receive count towards their out-of-pocket obligation. By passing this law, DC will join 14 other states (Arkansas, Arizona, Connecticut, Georgia, Illinois, Kentucky, Louisiana, Maine, Oklahoma, North Carolina, Tennessee, Washington, West Virginia, and Virginia) and Puerto Rico in protecting consumers by assuring their copay assistance will count towards cost-sharing obligations.
We, the undersigned 105 organizations, on behalf of millions of patients and Americans who live with complex conditions such as HIV, autoimmune diseases, cancer, diabetes, kidney disease, lupus, hemophilia, mental illness, and hepatitis write in response to the Federal Trade Commission (FTC) request for public comment on the impact of pharmacy benefit manager (PBM) practices on consumers. Specifically, we offer comments on how PBMs impact the health and well-being of patients who receive their health coverage through the private insurance market. While most people think insurers make the majority of decisions regarding health coverage and affordability, when it comes to prescription drugs, it is the PBMs that drive much of the decisions as to what medications a beneficiary can access and how much they pay for them. We commend the FTC for its leadership to investigate the impact that PBM practices have on the patient communities we serve and believe this represents a critical step forward to improving patient access and affordability to necessary medications.