Comment Letter

Neurosurgery Joins Alliance in Commenting on Network Adequacy

  • Reimbursement and Practice Management

Chiquita Brooks-LaSure, JD
Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS-9911-P
P.O. Box 8016
Baltimore, MD 21244-8016

RE: Patient Protection and Affordable Care Act; HHS Notice of Benefit and Payment Parameters for 2023

Dear Ms. Brooks-LaSure,

The Alliance of Specialty Medicine (the “Alliance”) represents more than 100,000 specialty physicians across 15 specialty and subspecialty societies. The Alliance is deeply committed to improving access to specialty medical care through the advancement of sound health policy. On behalf of the undersigned members, we write to provide feedback on the aforementioned proposed rule.

Prohibition on discrimination (§ 156.125)

The Alliance supports the Agency’s proposal to revise its regulations to ensure that benefit designs, particularly benefit limitations and plan coverage requirements, are based on clinical evidence.

Adverse tiering that limits access to prescription drugs for chronic health conditions or highly specialized surgical care are perfect examples of discriminatory benefit designs that specialists contend with frequently. As we’ve shared before, in the prescription drug context, formulary decisions are almost exclusively influenced by financial considerations rather than clinical data, especially when it comes to specialty medicines. This is concerning for patients who rely on life-saving medications for chronic and terminal illnesses, including cancer, rheumatoid arthritis, age-related macular degeneration, heart disease and many other diseases diagnosed, treated, and managed by specialists.

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