On Jul 23, 2021, Aimed Alliance submitted a comment in response to the “Request for Information Regarding Reporting on Pharmacy Benefits and Prescription Drug Costs” (RFI). In the RFI, the U.S. Departments of the Treasury, Labor, and Health and Human Services (“Departments”) proposed that health plans report rebates, fees, and any other remuneration paid by drug manufacturers to the plans. In determining how to define “rebates, fees, and other remunerations,” the Departments asked how to account for manufacturer copay assistance programs, coupon cards, and copay accumulator programs. Aimed Alliance recommended that the Departments 1) exclude copay assistance from the definition of “rebates, fees, and other remuneration”; 2) reinstate patient protections regarding copay accumulator programs; and 3) in the alternative, require insurers to report on copay accumulator programs in efforts to measure harm to patients and identify bad actors. Read our comment here.