Testimony, Comments, & Letters

While the Affordable Care Act (ACA) provides the opportunity for the Secretary of Health and Human Services (HHS) to periodically review the definition of Essential Health Benefits (EHBs), we caution HHS from making any changes or developing any new framework that would reduce the level of prescription drug coverage for beneficiaries. We believe that the current framework and requirements governing prescription drugs that are based on benchmark plans and allow states to add additional benefits are generally working well for patients. Our biggest concerns are the lack of adequate prescription drug coverage, the lack of enforcement of all EHB regulations, and allowing insurers and pharmacy benefit managers (PBMs) to skirt the EHB law and regulations. Below are our recommendations to strengthen prescription drug coverage and enforcement of existing EHB protections.