On behalf of the HIV+Hepatitis Policy Institute, an organization dedicated to promoting quality and affordable healthcare for people living with or at risk of HIV, hepatitis, and other serious and chronic health conditions, we thank you for this opportunity to comment on a National Coverage Determination (NCD) by the Centers for Medicare and Medicaid Services (CMS) on the use of provider-administered pre-exposure prophylaxis (PrEP). The first provider-administered medication for HIV pre-exposure prophylaxis (Apretude or cabotegravir as PrEP) was approved by the Food and Drug Administration in January 2022. In August 2022, we wrote to you on behalf of 64 organizations to request that CMS quickly and efficiently evaluate provider-administered PrEP for a National Coverage Determination, which is the only pathway to coverage under Medicare Part B. We commend CMS on moving forward with the NCD process and urge CMS to approve the NCD for provider-administered PrEP.
Comments in support of adding HIV to Medicare medication therapy management
We offer our strong support of adding HIV/AIDS as one of the chronic conditions to be included in the Medicare Part D Medication Therapy Management (MTM) program. The MTM program is designed to assure, with respect to targeted beneficiaries, that covered Part D drugs are appropriately used to optimize therapeutic outcomes through improved medication use, and to reduce the risk of adverse events, including adverse drug interactions.
50 patient groups comment in response to the request for information on essential health benefits [CMS-9898-NC]
We believe that the EHB regulations governing prescription drugs have generally been working well for patients; however, we propose some areas for improvement and are very concerned that there has been a lack of enforcement of the EHB regulations, an erosion of essential health benefits over the years, and some insurers and pharmacy benefit managers (PBMs) are devising ways to skirt the intent of the EHB law and regulations.
71 patient groups comment on the NBPP for 2024 proposed rule
We, the undersigned 71 organizations, on behalf of millions of patients and American consumers who live with complex conditions such as HIV, autoimmune diseases, cancer, diabetes, lupus, hemophilia, mental illness, hepatitis, neurological diseases, and other chronic illnesses, write to comment on the Notice of Benefits and Payment Parameters for 2024 Proposed Rule. The patients we represent appreciate all you are doing to make healthcare more accessible and affordable for beneficiaries. While there are several components of the Proposed Rule that many of us will comment on elsewhere, this letter focuses on those issues that impact access and affordability of prescription drugs.
Comments on USPSTF draft research plan on PrEP
The HIV+Hepatitis Policy Institute thanks you for the opportunity to comment on the U.S. Preventive Services Task Force (USPSTF) Draft Recommendation Statement: Prevention of Human Immunodeficiency Virus (HIV) Infection: Preexposure Prophylaxis (PrEP). On October 1, 2022, HIV+Hep submitted a request, supported by 62 additional organizations, asking the USPSTF to update the existing PrEP recommendation to include long-acting injectable PrEP. We commend you for conducting and completing this timely and thorough update.