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.
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.
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.
I would like to highlight the direct impact of PBM actions on patients, specifically on whether they can access the drug that their provider prescribes and the cost they will pay. Much of this is carried out behind the scenes and without regulation. However, that is beginning to change with more states passing bipartisan legislation to regulate PBMs and even the very partisan Congress is working on federal legislation that will hopefully pass this year.
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.