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Mercer and ERIC Comment Letter to CMS on Reporting on Pharmacy Benefits and Prescription Drug Costs (PDF)
The ERISA Industry Committee [ERIC] and Mercer
[Opinion] Feb. 1, 2022 "Some employer-sponsored medical benefits (such as expatriate plans, standalone telehealth plans, and other unique benefit designs) provide insignificant coverage of prescription drugs. Requiring these plans to report prescription drug information would be statistically inconsequential and would not benefit the Departments.... Currently, there are many programs offered to employers called copay maximizer and accumulator programs that allow the value of these programs to be captured by plan sponsors.... The Departments' approach excludes this type of cost-sharing assistance from the definition of 'prescription drug rebates, fees and other remuneration.' " MORE >> |
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