Comment on CMS-2026-2081-0001
National Pharmaceutical CouncilSupportAdvocacy
Summary: The National Pharmaceutical Council (NPC) supports the comprehensive review of the Essential Health Benefits (EHB) framework and advocates for specific improvements. They recommend prohibiting cost-management strategies like accumulators and maximizers, ensuring robust coverage for innovative brand and generic drugs, and updating drug classification systems to better reflect modern clinical guidelines.
The National Pharmaceutical Council (NPC) thanks CMS for the opportunity to respond with comments on the Comprehensive Review of the Essential Health Benefits Framework and Typical Employer Plan Standard RFI. NPC serves patients and society with policy-relevant research on the value of patient access to innovative medicines and the importance of scientific advancement. We envision a world where advances in medicine are accessible to patients, valued by society, and sustainably reimbursed by payers to ensure continued innovation.
Please see our full letter, uploaded.