United States of Care Responds to Request for Information by the IRS, EBSA, & CMS on Free Over-the-Counter Preventive Services

On December 4, United States of Care (USofCare) submitted comments to the Internal Revenue Service (IRS), Employee Benefits Security Administration (EBSA), and the Center for Medicare & Medicaid Services (CMS) in response to its Request for Information (RFI) for Coverage of Over-the-Counter Preventive Services. The RFI seeks feedback regarding the implications of a potential requirement for health plans and insurance issuers to cover over-the-counter (OTC) preventive services without cost-sharing or a prescription.

USofCare strongly advocates for the elimination of out-of-pocket costs for basic health services, which is why access to preventive care, currently guaranteed at zero cost-sharing under the Affordable Care Act (ACA), remains a top policy priority. USofCare has long fought to protect free access to preventive services, currently in jeopardy due to the pending Braidwood v. Becerra case.

USofCare appreciates the Administration’s consideration of policies to ensure people have access to free OTC preventive care. While the Departments raise several operational and clinical questions in its RFI, USofCare believes that the consumer experience ought to be centered as federal policymakers consider future action on this issue. To that end, our response raises key cautions and policy considerations that will need to be addressed in order to make sure that all people have equitable access to free OTC preventive services.

USofCare is appreciative of the opportunity to comment on this RFI.