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When CMS issued its Final Rule for the 2020 Annual Notice of Benefit and Payment Parameters, it included language designed "to encourage enrollees' use of lower-cost generic drugs."

Specifically, CMS stated that "beginning in 2020, we will allow individual market, small group, large group and self-insured group health plans to except from the maximum out-of-pocket limit cost sharing amounts paid using drug manufacturer coupons for specific prescription brand drugs that have an available and medically appropriate generic equivalent."

This well-intentioned release has triggered an avalanche of confusion and conflicting commentary throughout the industry, spanning the entire spectrum from question on what "specific prescription drugs" means (will CMS be releasing some sort of list of drugs?), to what other types of manufacturer/third party assistance, if any, could be included given the specific reference only to "coupons," to whether this guidance has any impact on situations in which there is not a "medically appropriate generic equivalent" available.