While we support the Maryland Prescription Drug Affordability Board (PDAB) goal of addressing affordability of treatments, we believe that the current approach of the Board to set upper payment limits (UPLs) on the proposed drugs for review will neither benefit patient health outcomes nor result in reduced out-of-pocket costs for patients.
We voice our strong support for Rhode Island’s H 8041 (“An Act Relating to Insurance—Prescription Drug Benefits”) which stipulates that, when calculating an enrollee’s overall contribution to any out-of-pocket maximum or any cost-sharing requirement under a health plan, an insurer or pharmacy benefit manager shall include any amounts paid by the enrollee or paid on behalf of the enrollee by another person. We thank you for considering this legislation and are pleased to offer our support.
We believe Maryland policymakers should focus on those issues that directly impact patients, such as PBM regulation and reform, standard plan designs with reasonable deductibles and nominal copays, and ensuring copay assistance counts. We note that the General Assembly is currently considering HB 879, legislation that would ensure that copay assistance programs will count toward deductibles and out-of-pocket maximums, and the Senate is considering SB 595.
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.
We believe policymakers should focus on those issues that directly impact patients, such as PBM regulation and reform, standard plan designs with reasonable deductibles and nominal copays, and ensuring copay assistance counts. We realize that Illinois has taken many of these steps already, and that Illinois policymakers are advocating for change at the national level, too, but more can be done.