102 Patient Groups Urge HHS to Reduce Patient Cost-Sharing for Prescription Drugs

Today, the I Am Essential coalition submitted comments, signed by 102 patient groups, to the U.S. Department of Health and Human Services in response to the President’s Blueprint to Lower Drug Prices and Reduce Out-of-Pocket Costs. The  comments focus on proposals contained in the Request for Information (RFI) that address efforts to reduce patient cost-sharing for prescription drugs in qualified health plans.
In their comments, the groups explain the importance of access to medications to maintain healthy and full lives, prevent and cure diseases, and keep patients alive, particularly for those with chronic and serious health conditions. However, patients are bearing a greater share of healthcare costs at the pharmacy as a result of changes in plan benefit design by insurance companies that include high deductibles, high out-of-pocket maximums, along with rising copays and co-insurance. These are impacting patient adherence and increasing medication abandonment.
In order to address the situation, I Am Essential suggests a number of proposals, including keeping prescription drugs outside the plan deductible or establishing a separate low drug deductible. In the letter, the patient groups site studies that show that such plans have a minimum impact on premiums.
Establishing reasonable copays, rather than high co-insurance, is another proposal the patient groups advanced. In the letter, they  emphasize that “when faced with a 50 percent cost-sharing responsibility on the full price of a drug, patients will undoubtedly have to make tough decisions, potentially leaving their prescriptions at the counter.”
Several states have already passed legislation that place copay caps on patient cost-sharing for medications while federal legislation has been proposed that the groups urge the Administration to support.
I Am Essential also urges the Administration to enforce ACA nondiscrimination patient protections and ensure that insurers do not place all drugs from the same class on the highest tier. “Unfortunately, insurers are not always following these laws and regulations, and federal and state governments are not doing enough to monitor plan design and take action against insurers for discriminatory plan design.”
Finally, I Am Essential discusses the importance of copay cards as a way for patients to access medications due to high patient cost-sharing and encourages the Administration to look into a new practice that many insurance plans and pharmacy benefit managers (PBMs) are instituting called copay accumulators. These policies prevent copay assistance contributions from counting towards a beneficiary’s deductible and maximum out-of-pocket spending limits. They can result in thousands of dollars in additional costs for patients. On top of that, insurers and PBMs are not alerting beneficiaries about this benefit change in a transparent fashion.
The letter concludes “I Am Essential appreciates the Administration’s commitment to helping patients access their medications by exploring ways to lower drug pricing and reduce their out-of-pocket costs. We hope you will consider the proposals we have offered. We believe they will help lower patient cost sharing and at the same time improve access to necessary medications and help improve the health and wellbeing of beneficiaries.”
Signatories to the letter include American Autoimmune Related Diseases Association, Arthritis Foundation, Chronic Disease Coalition, Epilepsy Foundation, Lupus Foundation of America, Mental Health America, Multiple Sclerosis Foundation, National Alliance on Mental Illness,  National Hemophilia Foundation, and The AIDS Institute.
The full text of the comment letter and list of 102 signers can be viewed here.


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