Aimed Alliance Submits a comment on the NBPP 2022

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On December 30, 2020, Aimed Alliance submitted a comment to the Centers for Medicare and Medicaid Serviced (CMS) on its “HHS Notice of Benefit and Payment Parameters for 2022” (NBPP 2022). The comment urged CMS to reinstate limitations on the use of copay accumulator programs as set forth in the NBPP 2020. The NBPP 2020 limited the use of copay accumulator programs to instances in which both a brand and generic medication were available. It incentivized cost savings by steering patients to generic medications when available, but it also recognized that copay accumulator programs are inappropriate when there is no generic alternative. The NBPP 2021 revoked those protections, and the NBPP 2022 is silent on this issue. Given the significant increase in plans adopting a copay accumulator program under NBPP 2021 and the ongoing COVID-19 pandemic, the comment urges CMS to reinstate the NBPP 2020 protections as they relate to copay accumulator programs.

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