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105 groups comment on the role of PBMs on patient access and affordability of prescription drugs

May 24, 2022

We, the undersigned 105 organizations, on behalf of millions of patients and Americans who live with complex conditions such as HIV, autoimmune diseases, cancer, diabetes, kidney disease, lupus, hemophilia, mental illness, and hepatitis write in response to the Federal Trade Commission (FTC) request for public comment on the impact of pharmacy benefit manager (PBM) practices on consumers.  Specifically, we offer comments on how PBMs impact the health and well-being of patients who receive their health coverage through the private insurance market.  While most people think insurers make the majority of decisions regarding health coverage and affordability, when it comes to prescription drugs, it is the PBMs that drive much of the decisions as to what medications a beneficiary can access and how much they pay for them.  We commend the FTC for its leadership to investigate the impact that PBM practices have on the patient communities we serve and believe this represents a critical step forward to improving patient access and affordability to necessary medications.

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Patient groups comment letter on 2023 health plan proposed rule

Jan 27, 2022

We, the undersigned 51 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, and hepatitis, write to comment on the Notice of Benefits and Payment Parameters for 2023 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.

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Comments on drug pricing transparency interim final rule [CMS-9905-IFC]

Jan 21, 2022

We are pleased that the Biden administration is moving forward with the requirement that insurance plans must report on various data points associated with prescription drug spending. We believe with this greater understanding and transparency of prescription drug costs, you can better implement policies and measures that increase competition, improve prescription drug affordability and access for the American people.

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Comments on prescription drug limitations in proposed Oregon Medicaid waiver

Jan 7, 2022

The HIV+Hepatitis Policy Institute write[s] to express our strong opposition to the proposed limits to the prescription drug formulary that have been included as part of Oregon’s 1115 Medicaid Demonstration Waiver. The stated goal of the waiver is to promote greater equity; however, not only do we believe what Oregon is proposing is not legal, but it will have the opposite effect of promoting equity. We urge you to not include these proposals in your waiver submission.

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Comments on draft hepatitis federal implementation plan

Nov 19, 2021

We cannot achieve the goal of ending hepatitis without increased funding for the key elements of the strategy, including testing, treating, and vaccination. Increasing resources for hepatitis elimination must be our first priority. While this draft hepatitis federal implementation plan was drafted with current resources in mind, there are areas where we would suggest some strengthening.

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