While the Affordable Care Act (ACA) provides the opportunity for the Secretary of Health and Human Services (HHS) to periodically review the definition of Essential Health Benefits (EHBs), we caution HHS from making any changes or developing any new framework that would reduce the level of prescription drug coverage for beneficiaries. We believe that the current framework and requirements governing prescription drugs that are based on benchmark plans and allow states to add additional benefits are generally working well for patients. Our biggest concerns are the lack of adequate prescription drug coverage, the lack of enforcement of all EHB regulations, and allowing insurers and pharmacy benefit managers (PBMs) to skirt the EHB law and regulations. Below are our recommendations to strengthen prescription drug coverage and enforcement of existing EHB protections.
Letter to Congressman Craig Goldman supporting the Prior Authorization Accountability Act
We write to express our strong support for the Prior Authorization Accountability Act (H.R. 9396), which recently passed the Subcommittee on Health on a bipartisan basis. We thank you for your leadership in advancing meaningful transparency in the prior authorization process and urge Congress to swiftly pass this important legislation. For patients living with HIV, viral hepatitis, and other serious chronic conditions, prior authorization is too often an unnecessary barrier to timely, medically appropriate care. While our organization believes prior authorization should be significantly reduced across the healthcare system, greater transparency is an essential step toward accountability and reform.
Letter to House Ways and Means Committee supporting HR9504’s 340B transparency provisions
The 340B program is essential to HIV prevention and treatment. It was created to help safety-net providers, including HIV and STD clinics, stretch limited resources in order to serve more low-income and uninsured patients. We strongly support preserving the program so that care can be delivered to those who otherwise would be out of reach.
Comments to Administrator Oz on the CMS proposed rule on interoperability standards and prior authorization for drugs
We appreciate the opportunity to provide feedback on these proposed standards. We emphasize that technical optimization must not serve to validate or expand the current overuse of utilization management. The true measure of successful regulatory reform is a meaningful reduction in the overall volume of PAs and restrictive step therapy protocols that patients and providers face daily. We urge the administration to enforce these reduction goals firmly and to pursue swift, coordinated interagency rulemaking to expand these electronic API, timeline, and transparency protections to the millions of individuals enrolled in health plans currently excluded from this rule.
Senate testimony on FY27 HIV and hepatitis program appropriations
In order to achieve successful implementation of the National HIV/AIDS Strategy (NHAS), EHE and viral hepatitis programs, resources are needed to strategically coordinate HIV and viral hepatitis activities across the federal government. We urge you to fund the HHS Office of Infectious Disease and HIV/AIDS Policy at $7.6 million.