Private Insurance

Support for Oregon enhancing transparency around the use of copay accumulators, copay maximizers, and alternative funding programs

Oct 11, 2024

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.

Substandard and discriminatory HIV medication coverage and plan design by Community Health Choice Texas

Oct 7, 2024

We are writing to express our continuing concern about substandard, discriminatory coverage of HIV treatment medications on Community Health Choice Texas “Premier” and “Select” health insurance plans. As we have previously stated, the formularies for these plans, among other things, do not meet the regulatory standards for formulary adequacy in CFR 156.122 (a)(3)(iii)(H) by failing to cover treatment regimens specified in broadly accepted treatment guidelines and that are indicative of clinical best practice, and by discouraging enrollment by people living with HIV.

Illinois testimony on PBM treatment of specialty drugs

Sep 11, 2024

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.

Concerns with Rhode Island Drug Cost Review Commission (S 2719)

May 14, 2024

Given the important nature of prescription drugs to the life-saving treatment of HIV and hepatitis B, and now the cure of hepatitis C and the prevention of HIV, we have long advocated for affordable access to prescription medications. We applaud your commitment to ensuring that beneficiaries can access and afford the prescription medications that their providers prescribe. While we support and share the committee’s intent to lower out-of-pocket costs for consumers, we believe the proposed Rhode Island Drug Cost Review Commission (S 2719) would neither benefit patients in the long run nor result in reducing patients’ costs.

Concerns with Rhode Island Drug Cost Review Commission (H 8220)

May 8, 2024

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. For example, Rhode Island still allows issuers to implement harmful copay accumulator adjustment policies that permit double-dipping by payers to take copay assistance without crediting beneficiary out-of-pocket costs.

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