We believe that the EHB regulations governing prescription drugs have generally been working well for patients; however, we propose some areas for improvement and are very concerned that there has been a lack of enforcement of the EHB regulations, an erosion of essential health benefits over the years, and some insurers and pharmacy benefit managers (PBMs) are devising ways to skirt the intent of the EHB law and regulations.
71 patient groups comment on the NBPP for 2024 proposed rule
We, the undersigned 71 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, hepatitis, neurological diseases, and other chronic illnesses, write to comment on the Notice of Benefits and Payment Parameters for 2024 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 2024 draft letter to issuers in the federally-facilitated exchanges
The HIV+Hepatitis Policy Institute commented on the 2024 Draft Letter to Issuers, praising CMS for planning to conduct adverse tiering review for HIV and hepatitis C medications but expressing disappointment that they continue to allow insurers to collecting copay assistance for drugs that is intended for beneficiaries.
Comments on the USPSTF draft research plan “Prevention of Human Immunodeficiency Virus (HIV) Infection: Preexposure Prophylaxis”
We urge the USPSTF to consider the following two recommendations as it finalizes its plan “Prevention of Human Immunodeficiency Virus (HIV) Infection: Preexposure Prophylaxis”: research should explicitly evaluate and describe the ancillary services that are integral to the PrEP intervention and the USPSTF should adopt a more nimble and timely review of the PrEP recommendation as new products see clinical trial success.
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.