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Comments on updated HIV & hepatitis strategic plans

Dec 5, 2024

As a policy and advocacy organization we work to ensure there are the proper policies, programs, and funding to implement the Strategic Plans. We also refer to them in our work with the Congress, media, and the public to help educate them on the strategic plans and national goals included in each of the plans. We use them to measure our progress in meeting the goals. We not only use them to advocate before the Congress but also within government agencies and leadership to hold them accountable to ensure the goals are reached and that proper policies and programs are in place with sufficient funding.

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Comments on the 2026 NBPP proposed rule

Nov 12, 2024

While we appreciate the many steps that you are taking to make healthcare more accessible and affordable for beneficiaries, the majority of this comment on the Proposed NBPP Rule focuses on the need for CMS and related federal agencies to take the necessary steps to increase access and affordability of prescription drugs that should have been included in the Draft NBPP Rule but were not.

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Comments on 2026 draft letter to issuers in the federally-facilitated exchanges

Nov 4, 2024

In our comments we reiterate our profound disappointment with CCIIO and state regulators for not enforcing the strong ACA nondiscrimination patient protections, including a prohibition on adverse tiering in drug formularies and the requirement to cover the drugs included in widely accepted treatment guidelines. We also outline a number of recent examples by insurers, including some new ones, that either CCIIO or states are permitting to operate that do not protect the interests of people living with HIV since they market discriminatory benefit plans designs.

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Support for Oregon enhancing transparency around the use of copay accumulators, copay maximizers, and alternative funding programs

Oct 11, 2024

As the Oregon legislature considers modifications to SB 844, we write to express our support for proposed legislative recommendations including enhancing transparency around the use of copay accumulators, copay maximizers, and alternative funding programs. In recent years, insurers and their PBMs have implemented harmful policies that shift financial responsibilities for prescription costs to patients by not applying copayment assistance from drug manufacturers and sometimes charitable organizations.

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Comments to Washington Prescription Drug Affordability Board on HIV treatment and cost of care

Sep 15, 2024

While patients currently have access to free or affordable HIV medications through various avenues, we are concerned that setting an arbitrarily low price for these treatments could negatively impact future drug development and reduce manufacturers’ willingness to continue providing medications to millions of people in underdeveloped and underserved nations. It is essential that manufacturers have the necessary incentives to invest in research and development, enabling the creation of longer-acting treatments, preventive drugs, vaccines, and potentially even a cure for the virus. Overlooking the impact of current assistance programs on HIV treatment affordability, as well as mandating alternative drug options, disregards the nuances of HIV care and the unique requirements of each patient.

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