Consumers for Quality Care Issues Statement on 2025 Notice of Benefit and Payment Parameters (NBPP)
By Consumers for Quality Care, on January 8, 2024
For Immediate Release
January 8, 2024
Contact: press@consumers4qualitycare.org
Consumers for Quality Care Issues Statement on 2025 Notice of Benefit and Payment Parameters (NBPP)
WASHINGTON, D.C. – Consumers for Quality Care (CQC), a coalition of advocates and former policy makers working to provide a voice for patients in the health care debate, issued the following comment on the final 2025 Notice of Benefit and Payment Parameters (NBPP) from the U.S. Department of Health & Human Services (HHS):
“Dear Secretary Becerra and Administrator Brooks-LaSure,
Consumers for Quality Care (CQC) is a coalition of advocates, former policymakers, and 35 patient and consumer advocacy organizations committed to providing a voice for patients in the health care debate. We appreciate the opportunity to submit our comments regarding the proposed HHS Notice of Benefit and Payment Parameters (Payment Notice) for the 2025 Benefit Year. Our organization is dedicated to advancing the interests and well-being of patients, and we commend the Centers for Medicare & Medicaid Services (CMS) for their ongoing efforts to address health disparities and promote health equity within the United States health care system. While we are pleased with the consumer protections outlined in the 2025 Notice of Benefits and Payment Parameters (NBPP), we urge the Centers for Medicare and Medicaid Services (CMS) to consider additional priorities to protect consumers.
CQC applauds CMS’s continued commitment to implementing standardized plans and network adequacy standards. For many Americans, choosing the right health care plan can be confusing and overwhelming, and standardized plans are an important tool to help ensure Americans have access to quality care. Standardized plans can also help improve health equity, as they simplify plan choice and usage for consumers while improving value for enrollees. We support CMS’s efforts to reduce the risk of plan choice overload, striking a balance between simplicity and the availability of plans that cater to diverse health needs. Most importantly, standardized options can help consumers more easily identify plans with discriminatory benefit designs that penalize individuals with certain health conditions or disabilities by leaving them with substantial out-of-pocket costs.
While CQC appreciates the standardized plan improvements presented in the 2025 NBPP that reaffirm the 2024 NBPP, we believe CMS must take action to reduce other out-of-pocket costs for consumers.
We are disappointed to see that copay assistance accumulator programs are not addressed in the 2055 NBPP. Copay accumulators shift costs from insurance companies to patients. This year, a federal court decision affirmed that consumers should be able to use pharmaceutical manufacturers’ coupons to reduce the out-of-pocket costs of their prescription medications at the pharmacy counter without being penalized by their insurance company.
In 2020, CMS proposed a copay assistance rule that would allow patients to receive the assistance they so desperately need for critical medications that do not have a generic equivalent. This important addition to the 2025 NBPP would alleviate some anxiety around health care cost that many Americans face daily and help protect consumers from costs that should be covered by their insurance.
We appreciate the CMS’s dedication to advancing health equity and addressing disparities through the proposed rule and believe that the outlined changes will contribute to an improved healthcare system that better serves the diverse needs of patients across the nation. To learn more about the harm that can be caused by copay accumulators, we urge you to view CQC’s recent consumer awareness video. For more information on initiatives consumers want to see to help lower their costs, we urge you to review CQC’s 2022 Negotiator’s Guide to Health Care Reform.
Sincerely,
Consumers for Quality Care”
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ABOUT
Consumers for Quality Care (CQC) is a coalition of advocates and former policymakers working to provide a voice for patients in the health care debate as they demand better care. CQC is led by a board of directors that includes the Honorable Donna Christensen, physician and former Member of Congress; Jim Manley, former senior advisor to Senators Edward Kennedy and Harry Reid; Jason Resendez, community advocate and health care strategist; and Mary L. Smith, former head of Indian Health Service.