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Prior authorization has been popular with the insurance industry because it works. This is known as the sentinel effect, and in the initial stages, providers accommodated the process without much complaint. The health insurance industry didn’t have many other tools to suppress demand, so it went with the sentinel effect by default.
Coverage of Anti-Obesity Medications (AOMs) The NHC applauds CMS for aligning with the medical community and proposing to recognize obesity as a chronic disease and allow Medicare Part D coverage for AOMs. Below, we provide detailed comments and recommendations on key provisions of the proposed rule.
We believe that patient-centric engagement is essential to ensure that the negotiation process leads to outcomes that genuinely benefit patients. 1 And we appreciated CMS’ thorough responses to comments for IPAY 2026 and hope the Agency will replicate this for this comment opportunity.
The NBPP is a set of rules and guidelines issued annually by CMS that outline the policies and standards for health insurance plans and issuers, primarily focusing on the Health Insurance Marketplace under the Affordable Care Act. These are the rules for the federal health insurance marketplace for the coming year.
The NHC appreciates CMS’ efforts to gather patient-centered data as part of this ICR and its commitment to making the process more relevant for patients and patient organizations. While we acknowledge these improvements, it is important to note that some aspects of the data collection process may remain challenging.
Making available more specific information about total costs and coverage will ensure that all consumers have comprehensive information to help them make smart health care decisions. These resources should aim to clarify insurance terms and concepts, aiding consumers in navigating the complexities of selecting a health plan.
. – Considering that the government promotes companies to “Make in India”, we request that the time limit for commencing manufacturing or production be further extended to 31 March 2026. Therefore, the sunset period should be extended for borrowings in foreign currency up to 31 March 2026; this would support the vision of “Make in India”.
Under the new Manufacturer Discount Program, manufacturers will be required to provide discounts on applicable drugs during the initial coverage phase and catastrophic phase of the defined standard Part D drug benefit.
Congress left Medicare drug pricing to the drug manufacturers, pharmacies, and insurance plan sponsors to determine, and expressly prohibited the government from “interfering” in those private price negotiations under the so-called “Non-Interference Clause” of the Medicare Modernization Act of 2003.
General Support for CMS Proposals The NHC commends CMS for its ongoing commitment to advancing health equity, improving access to care, ensuring program integrity, and maintaining affordability through Marketplace coverage. Copay Assistance and Drug Coverage in Large Group Plans Accumulator Adjustment Programs and Cost Sharing.
Overarching Comments The NHC acknowledges CMS efforts to implement meaningful policy updates in CY 2026 to advance equity, affordability, and access to high-value care for Medicare beneficiaries. 3 Establishing a feedback loop with stakeholders during this monitoring process will provide additional safeguards against adverse effects.
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