On January 27, 2023, the Centers for Medicare & Medicaid Services released a State Health Official (SHO) letter, “Medicaid Continuous Enrollment Condition Changes, Conditions for Receiving the FFCRA Temporary FMAP Increase, Reporting Requirements, and Enforcement Provisions in the Consolidated Appropriations Act, 2023.” The SHO letter is the second in a series of guidance related to section 5131 of the Consolidated Appropriations Act, 2023 (CAA), which established a fixed end date for the Medicaid continuous coverage requirement, a gradual phase-down for the enhanced federal match, and new guardrails for mitigating coverage loss for individuals who continue to be eligible. This expert perspective reviews the additional detail and operational expectations of states during the unwinding of Medicaid continuous coverage as laid out in the SHO letter.
Specialty Tier Pharmacy Benefit Designs in Commercial Insurance Policies: Issues and Considerations
Georgetown Health Policy Institute, Center on Health Insurance Reforms – Sally McCarty and David Cusano
As health care costs rise, one of the chief determinants of the rate of increase has been the cost of prescription drugs. Over time, additional tiers have been included in pharmacy benefit designs and, as they were added, cost sharing in the new, higher tiers has increased. With the enactment of the Affordable Care Act (ACA), which eliminated underwriting and imposed the federal minimum loss ratio (MLR), a limit on administrative and other non-healthcare spending, health insurers have looked to pharmacy benefit designs as one of the few remaining mechanisms for controlling costs. As a result, tiered pharmacy benefit designs with as many as five or six tiers are emerging. These tiered pharmacy benefit designs could significantly affect the affordability of prescription drug therapies for those who need them most, and could also potentially violate the anti-discrimination policies of the ACA. This issue brief, prepared by the Georgetown Health Policy Institute’s Center on Health Insurance Reforms, examines these issues and explores several regulatory approaches for how best to address them.