ALLIANCE OF COMMUNITY HEALTH PLANS, INC.

Medicare & Medicaid Issues: Medicare Advantage (Part C) and Prescription Drug (Part D) programs including quality measures and star ratings; third-party marketing tactics and broker compensation; prescription drug costs; risk adjustment; modernizing network composition and reforming benchmarks; advocated for differentiation in Medicare Part C and D reporting requirements; and transparency of Pharmacy Benefit Managers (PBMs). Medicaid: Advocated on the implementation of the Medicaid provisions in the One Big Beautiful Bill Act; Advocated to ensure state Medicaid agencies use all forms of data available before requesting information from an enrollee. Advocated in support of integration in Dual Eligible Special Needs Plans (D-SNPs) and advocated in support of redefinitions of HIDE-SNPs and FIDE-SNPs to ensure that states with behavioral health and LTSS carve-outs still qualify for the frailty adjustment. Prescription Drug Pricing: Advocated on implementation of Part D provisions of the Inflation Reduction Act; advocated on drug pricing models being developed by the Center for Medicare & Medicaid Innovation drug pricing models; advocated for affordable cell and gene therapy drugs including the creation of a national risk-pool model; advocated for an end to patent thickets which are a barrier to lower cost biosimilars and generics entering the market; advocated for a ban on direct-to-consumer advertisements of drugs, including an end to the tax breaks that pharmaceutical manufacturers receive associated with direct-to-consumer ads; advocated for increased transparency requirements on pharmaceutical manufactures to list wholesale acquisition costs in drug ads and for expanded authorities for the Food and Drug Administration to better conduct oversight of direct-to-consumer advertisements. Prior Authorization: Advocated on regulation addressing electronic prior authorization to improve consumers access to appropriate care in a timely fashion, reduce instances of inappropriate or low-value care; Advocated on ensuring that health plans and providers share equally in the development and implementation of electronic prior authorization requirements. Advocated on prior authorization criteria requirements that are realistic for community-based health plans. Telehealth: Advocated in support of permanent extension of telehealth flexibilities, in support of the CONNECT for Health Act and Telehealth Modernization Act; Advocated in support of an extension of the Acute Hospital Care at Home Program waivers; Advocated for legislation to repeal the requirement that doctors see Medicare beneficiaries in person within six months of being treated virtually for mental and behavioral health concerns (Telemental Health Care Access Act). Provider Directories: Advocated on ensuring accuracy of provider directories including the creation of a national provider directory at CMS.

General Health Care Issues: Advocated on prescription drugs costs, including advocating for the transparency of PBMs and support for the Fair Accountability and Innovative Research (FAIR) Act; Advocated for patent reform and educated on the utilization of GLP-1s drugs; Advocated for the elimination of the separate interchangeability designation for biosimilars. Mental and Behavioral Health: advocated in support of integration, collaborative care and access to mental and behavioral health services; advocated for greater access to mental and behavioral health services overall; advocated for greater access to tele-mental health services; advocated on mental health parity. Prior Authorization: Advocated on regulation addressing electronic prior authorization to improve consumers access to appropriate care in a timely fashion, reduce instances of inappropriate or low-value care; Advocated on ensuring that health plans and providers share equally in the development and implementation of electronic prior authorization requirements. Advocated on prior authorization criteria requirements that are realistic for community-based health plans.