12/25/2023 0 Comments Copay accumulator![]() In general, CAAPs fall into two types: copay accumulator programs and copay maximizer programs. The rule allows CAAPs to be administered by health plans in the ACA and commercial market without restricting those programs to only brand drugs with an existing generic alternative as proposed the year prior.ĬMS essentially gave insurers the go-ahead for CAAPs, likely leading to increased utilization of said programs in 2021. After tabling the subject for a year, CMS finalized rulemaking in their 2021 ACA NBPP Final Rule : This proposed rule was never finalized due to a conflict and the resulting confusion with an IRS notice from 2004 outlawing the contribution of coupon assistance towards deductibles in high-deductible/HSA plans. ![]() Back in 2019, when CMS issued their 2020 ACA Notice of Benefit and Payment Parameters (NBPP) Proposed Rule, they sought to prohibit CAAPs for brand drugs lacking generic competition.
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