Comments

Comments to CCIIO on the 2027 Draft Letter to Issuers in the Federally-Facilitated Exchanges

We urge CMS to prioritize oversight of the Marketplace, which serves as an essential safety net within the country’s health insurance system and is of critical importance to people affected by HIV and other serious and chronic health conditions.  We urge CCIIO to reject proposals that decrease access to care by weakening network adequacy, time and distance, and ECP standards; enforce existing rules requiring copay assistance to count towards patient cost-sharing and that covered drugs are considered EHB; and improve the tools CMS provides to regulators to detect formulary coverage that deters enrollment by people living with HIV. As the key regulator of health insurance in the United States, we urge CCIIO to ensure that Marketplace plans provide meaningful, affordable, and non-discriminatory coverage to all. 

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Comments on 2027 Notice of Benefits and Payment Parameters proposed rule

HIV+Hep submitted comments on the 2027 NBPP proposed rule writing it jeopardizes insurance access and affordability by failing to define “cost-sharing” to include copay assistance and all covered drugs as “essential health benefits” in large group and self-funded plans, and failing to address “alternative funding plans.”

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Comments to CMS Administrator Oz opposing the Guarding U.S. Medicare Against Rising Drug Costs (GUARD) model

The HIV+Hepatitis Policy Institute strongly opposes the GUARD Model because it prioritizes projected federal savings over the health and financial stability of Medicare beneficiaries. By moving forward with a framework that acknowledges multibillion-dollar cost increases for patients and relies on a retrospective monitoring system, CMS leaves those who depend on continuous, life-sustaining treatment without meaningful protection from harm. We urge CMS to withdraw this proposal and instead pursue alternative reforms that offer immediate, point-of-sale affordability without jeopardizing treatment access, destabilizing essential safety nets, or undermining the research and development necessary to reach future therapeutic advances and cures.

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Comments to Colorado Dept of Health Care Policy & Financing supporting the prohibition of prior authorization for HIV treatment and prevention in Medicaid

We urge Colorado to maintain the prohibition of prior authorization for HIV treatment and prevention in Medicaid. Timely access to guideline-recommended HIV treatment and prevention is critical for both individual and public health. These policies align with rapid scientific advancement. Reinstating prior authorization would disproportionately harm the most vulnerable. 

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Comments to MACPAC urging an exemption for people with HIV to the Medicaid community engagement requirement

As you develop your principles and policy options we urge MACPAC to recommend an explicit exemption for all people living with HIV from the community engagement requirement mandated by Public Law 119-21, also known as the One Big Beautiful Bill Act. People with HIV are living with a lifelong serious and complex medical condition and have special medical needs: they cannot stay healthy without continuous access to their lifesaving HIV treatment. Any gap in treatment risks serious health consequences, including failure of viral suppression and the risk of onward transmission. Longer treatment gaps are potentially disabling, allowing progression to AIDS, after which life expectancy is limited.

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