ACA

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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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Substandard and discriminatory HIV medication coverage and plan design by Community Health Choice Texas

Oct 7, 2024

We are writing to express our continuing concern about substandard, discriminatory coverage of HIV treatment medications on Community Health Choice Texas “Premier” and “Select” health insurance plans.  As we have previously stated, the formularies for these plans, among other things, do not meet the regulatory standards for formulary adequacy in CFR 156.122 (a)(3)(iii)(H) by failing to cover treatment regimens specified in broadly accepted treatment guidelines and that are indicative of clinical best practice, and by discouraging enrollment by people living with HIV.

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Concerns with Rhode Island Drug Cost Review Commission (S 2719)

May 14, 2024

Given the important nature of prescription drugs to the life-saving treatment of HIV and hepatitis B, and now the cure of hepatitis C and the prevention of HIV, we have long advocated for affordable access to prescription medications. We applaud your commitment to ensuring that beneficiaries can access and afford the prescription medications that their providers prescribe. While we support and share the committee’s intent to lower out-of-pocket costs for consumers, we believe the proposed Rhode Island Drug Cost Review Commission (S 2719) would neither benefit patients in the long run nor result in reducing patients’ costs.

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Support for NH SB 354 relative to insurance cost-sharing calculations

Apr 29, 2024

It is a pleasure to reiterate our strong support for Senate Bill 354-FN (“relative to insurance cost-sharing calculations”) which would require health insurers and pharmacy benefit managers to include any amount paid by the enrollee or on their behalf in calculating an enrollee’s contribution to cost-sharing requirements. Now that the Senate successfully passed the bill, we are pleased that you will be holding a hearing on this important issue and that you too will pass the bill.

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