The Association for Clinical Oncology (ASCO) submitted comments in response to the Centers for Medicare & Medicaid Services’ (CMS) Patient Protection and Affordable Care Act 2024 Notice of Benefit and Payment Parameters proposed rule. ASCO’s comments support proposals aimed at reducing or eliminating gaps in health care coverage, and the Association continues to advocate for beneficiary protections by opposing the use of copay accumulator programs.
ASCO supports CMS’ proposals to allow health insurance Marketplaces to adopt special enrollment periods (SEPs) for individuals losing Medicaid or CHIP coverage, and individuals who attest to a future loss of minimum essential coverage (MEC), to eliminate and/or reduce any gaps in coverage. In the coming months, a higher-than-usual volume of individuals is expected to transition from Medicaid and CHIP coverage to a Marketplace plan.
On March 31, 2023, states may begin terminating Medicaid coverage for those who no longer qualify due to the end of the COVID-19 Public Health Emergency. ASCO is committed to supporting policies that allow individuals to access affordable insurance without interruption, and the Association agrees with CMS that the proposed changes would likely increase access to continuous health care coverage.
While ASCO appreciates the efforts CMS made in its proposal to improve access to health care coverage under the Exchanges, the Association is extremely disappointed that the agency did not reverse the copay accumulator policy that was finalized in the 2021 Notice of Benefit and Payment Parameters final rule.
Insurers currently do not have to factor in the copay assistance a patient receives when determining whether an enrollee has met their annual deductible and/or out-of-pocket limit, which disproportionately impacts patients with cancer and other chronic illnesses. Such utilization management tactics negate the intended benefit of patient assistance programs—and remove a safety net for patients who need specialty medications but cannot afford them. ASCO strongly opposes the use of copay accumulator and copay maximizer programs for patients with cancer and continues to urge CMS to eliminate harmful utilization management tactics.
Read the full comment letter.
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