NPC Comments on HHS Notice of Benefit and Payment Parameters for 2025

In this comment letter, NPC offers input on HHS' Notice of Benefit and Payment Parameters for 2025, annual rulemaking that governs programs and health plans offered under the Affordable Care Act.

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NPC submitted comments to the Centers for Medicare & Medicaid Services (CMS) in response to the notice of proposed rulemaking, “Patient Protection and Affordable Care Act, HHS Notice of Benefit and Payment Parameters for2025; Updating Section 1332 Waiver Public Notice Procedures; Medicaid; Consumer Operated and Oriented Plan (CO-OP) Program; and Basic Health Program [CMS-9895-P].”

NPC’s comments and recommendations focus on key issues within the proposed rule, including:

  • Replacing the United States Pharmacopeia (USP) Medicare Model Guidelines (MMG) with the USP Drug Classification (DC) System
  • Risk Adjustment Model Recalibration
  • Consumer Representation on Pharmacy & Therapeutics (P&T) Committees
  • Clarifying and Codifying Essential Health Benefits (EHB) Policy for Drugs Covered in Excess of the Benchmark
  • Copay Accumulators
  • Drug Tiering

Read all of NPC's recommendations in the comment letter.

Read the full comment letter