Sign on to IAE’s Response to the 2020 Notice of Benefit and Payment Parameters

The “I Am Essential” coalition has prepared draft comments for organizational sign-on in response to the Administration’s 2020 Notice of Benefit and Payment Parameters (NBPP). The NBPP includes a wide range of proposed changes to qualified health plans that would, if finalized, add costs and reduce access to care for beneficiaries. Our comments focus on the proposals that could jeopardize broad access to prescription drugs while placing increased cost-sharing on patients.  

I Am Essential patients often rely on copay assistance programs to help them afford the cost of prescription drugs. Among other problematic proposals, the NBPP proposes allowing insurance companies to:

  • not allow the use of copay assistance for the purchase of brand drugs when a generic is available;
  • not count patient spending on brand drugs when a generic drug is available;
  • remove brand drugs from formulary mid-year when a generic becomes available.

We also comment on provisions related to setting the amount of premium tax credits and urge CMS to enforce patient protections already set in statute and regulation.  

We encourage your organization to sign on and to feel free to utilize it as your organization prepares its own comments.  Comments are due Tuesday, February 19th and you can submit your own at

To sign on to the letter, please fill out this form by 2pm EST, Tuesday, February 19, 2019. 

Please feel free to distribute this letter to your networks. If you need any assistance, please contact Rachel Klein at


Thank you, 

Carl Schmid, Deputy Executive Director, The AIDS Institute  

Laura Widener, Vice President, Government Relations and Advocacy, Epilepsy Foundation 

Andrew Sperling, Director of Federal Legislative Advocacy, National Alliance on Mental Illness

Media Contact
Carl Schmid(202) 669-8267

For Media Inquiries, please contact Carl Schmid of The AIDS Institute.



Sign on to I Am Essential Draft Comments for 2020 Notice of Benefit and Payment Parameters