The National Black Leadership Commission on Health, the nation’s oldest non-profit organization dedicated to serving Black/African American populations, strongly urges the U.S. Centers for Medicare & Medicaid Services (CMS) to immediately stop the pending CMS proposed rule changes pertaining to co-pay assistance and line extension definitions. Any purported “cost containment” benefits that could theoretically be realized under such proposals must be seriously weighed against the very real impact on patients’ health and access to critical treatments for present day and future medical innovations.
According to recent reports, these proposed policy changes could severely limit patient access, force pharmaceutical manufacturers to end critical cost-sharing assistance programs for patients, and cripple the very future of pharmaceutical innovations to which patients desperately need access. Further, the CMS proposed rule comes months after the Trump administration finalized the Notice of Benefit and Payment Parameters (NBPP) rule for 2021, which in part allows health plans to implement copay accumulator adjustment programs and prevents manufacturers’ from ensuring that the full value of cost-sharing assistance is passed on to patients.
Under normal circumstances, the proposed rule changes would greatly impact the populations our organization serves when it comes to access to and cost of prescription drug treatments. But within the midst of the COVID-19 health pandemic, implementation of such changes would most assuredly be devastating.
Black/African Americans are at significantly higher risk for COVID-19 due to more likely having a pre-existing condition that would make them more vulnerable, including respiratory problems, obesity, heart disease, HIV/AIDS, and other chronic health issues. These individuals rely on prescription drugs to keep them healthy and provide an improved quality of life.
We must not lose sight of the potential negative impact of the CMS proposed rule change and urge CMS to stop moving forward. Now is not the time.
This is the time to attack lethal health disparities with solutions to fix the underlying problems that put black and brown families at greater risk of dying from the coronavirus. This is the time to reaffirm the urgent need to create a more equitable health care system by making quality, affordable health care more accessible to all Americans. If CMS is serious about addressing these inequalities, they need to stop undermining systems that work.
