Comment on CMS-2026-2081-0001

National Psoriasis FoundationSupportAdvocacy
Summary: The National Psoriasis Foundation (NPF) supports CMS's interest in a robust essential health benefit (EHB) framework but urges the agency to avoid reducing coverage in the name of affordability. They advocate for a "total patient lens" on costs, the enforcement of rules against copay accumulators and maximizers, and a thorough assessment before making material changes to the EHB framework.
The National Psoriasis Foundation (NPF) appreciates CMS's interest in ensuring a robust essential health benefit (EHB) framework and focusing on making health care affordable. We caution, however, against equating affordability with reduced coverage and recommend evaluating affordability through a total patient lens. Additionally, we urge CMS to issue promised rules that ban predatory insurance tactics, including copay accumulator adjustment programs and copay maximizers. Finally, we recommend that CMS not materially alter the EHB framework without robust assessment of how it is currently working. Our more detailed recommendations and comments are included in the attached document.

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