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.
Comments on drug pricing transparency interim final rule [CMS-9905-IFC]
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.
Comments on prescription drug limitations in proposed Oregon Medicaid waiver
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.
Comments on draft hepatitis federal implementation plan
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.
Comments in support of hepatitis B universal adult vaccination
HIV+Hep strongly supports a recommendation for universal hepatitis B vaccination for all adults. The hepatitis B vaccine is safe and effective, with over 1 billion doses administered worldwide and is estimated to have prevented over 310 million infections worldwide between 1990 and 2020. Despite highly effective vaccines, up to 2.4 million people in the United States may be living with chronic hepatitis B, and there are up to 80,000 new cases of hepatitis B each year. With the proper guidance and resources, each new infection is preventable.