ACS CAN Comments on 2021 Notice of Benefit and Payment Parameters

March 3, 2020

The American Cancer Society Cancer Action Network (ACS CAN) appreciates the opportunity to comment on the 2021 Notice of Benefit and Payment Parameters proposed rule. ACS CAN is making cancer a top priority for public officials and candidates at the federal, state, and local levels. ACS CAN empowers advocates across the country to make their voices heard and influence evidence-based public policy change, as well as legislative and regulatory solutions that will reduce the cancer burden. As the American Cancer Society’s nonprofit, nonpartisan advocacy affiliate, ACS CAN is critical to the fight for a world without cancer.

In general, we support many of the proposals contained in the 2021 Payment Notice, specifically the proposals related to special enrollment periods. Unfortunately, we are very concerned about the proposal to allow issuers to no longer count manufacturer coupons towards an individual’s limitation on cost-sharing. This policy could hinder cancer patients’ and survivors’ access to medically appropriate therapies. We urge HHS to rescind the proposed policy.

We are also concerned that HHS’ proposal related to auto-enrollment of individuals in zero premium plans is unduly burdensome and will create confusion for individuals. We urge HHS not to finalize the proposed policy.