Notice of Benefit and Payment Parameters for 2021
The National Health Council (NHC) appreciates the opportunity to comment on the Centers for Medicare & Medicaid Services’ (CMS’) Proposed Rule entitled, “HHS Notice of Benefit and Payment Parameters for 2021; Notice Requirement for Non-Federal Governmental Plans” (the NBPP).
Created by and for patient organizations 100 years ago, the National Health Council (NHC) brings diverse organizations together to forge consensus and drive patient-centered health policy. We promote increased access to affordable, high-value, sustainable health care. Made up of more than 140 national health- related organizations and businesses, the NHC’s core membership includes the nation’s leading patient organizations. Other members include health-related associations and nonprofit organizations including the provider, research, and family caregiver communities; and businesses representing biopharmaceutical, device, diagnostic, generic drug, and payer organizations.
The NHC recognizes that the long-term viability of the Patient Protection and Affordable Care Act (PPACA) is dependent on stability of the individual health plan marketplaces and supports policies that balance long-term program stability with our primary commitment to ensuring that individuals with chronic conditions have access to affordable, high-value, sustainable health care.
Our comments focus on the NBPP provisions most likely to facilitate or impede our goal of ensuring that all Americans, particularly those with chronic diseases and disabilities, can access the health care they need at a cost they can afford. Specifically, the NHC:
- Urges CMS to reconsider its proposal to modify automatic re-enrollment processes;
- Urges CMS to withdraw the proposed changes related to manufacturer coupons and leave in place the provision established in the 2020 NBPP; and
- Supports value-based insurance design with carefully considered guardrails and requirements.