September 05, 2019

ACA FAQ 40 Released

On August 26, 2019, CMS released a FAQ  on the relationship between the annual limitation on cost sharing under the ACA and the application of co-payment accumulators to prescription drug claims paid at least in part with manufacturer coupons. Regulators are permitting health plans to continue to use co-payment accumulators, regardless of whether a generic substitute exists, until the Notice of Benefit and Payment Parameters for 2021 is issued in the spring of 2020 and becomes effective on January 1, 2021.