On January 31, 2020, the Centers for Medicare & Medicaid Services (CMS) released the proposed Notice of Benefit and Payment Parameters for 2021 (NBPP 2021). The Notice of Benefit and Payment Parameters is an annual rule that outlines the benefit and payment policies that will govern health plans in the coming year. For the 2021 plan year, CMS has proposed to allow health plans to exclude the value of third-party financial assistance used from the calculation of enrollees’ cost-sharing requirements, including deductibles and maximum out-of-pocket costs. This policy is known as a “copay accumulator,” and it has grown in popularity among health plans in recent years.
The proposed copay accumulator policy is a shift from the rule that CMS proposed last year in the Notice of Benefit and Payment Parameters for 2020 (NBPP 2020), which would have only allowed health plans adopt copay accumulator programs when plan enrollees filled a prescription for a brand drug that had a generic equivalent.
On February 23, 2020, Aimed Alliance submitted a comment to CMS, opposing the NBPP 2021 copay accumulator rule and requesting that the NBPP 2020 rule be reinstated and enforced. Review our comment to learn more about this issue.