Though Connecticut’s statutory exclusion of antiretrovirals from the Medicaid Preferred Drug List has ended, we continue to oppose adding any antiretrovirals for HIV treatment or prevention to the PDL with non-preferred status, which would enable prior authorization and step therapy on those drugs.
While we share a commitment to addressing the high cost of prescription drugs, we have significant concerns with Virginia H.B. 1724 that creates a Prescription Drug Affordability Board (PDAB). We believe it will not translate into lower drug costs for patients and may dampen future drug development.
While we appreciate the many steps that you are taking to make healthcare more accessible and affordable for beneficiaries, the majority of this comment on the Proposed NBPP Rule focuses on the need for CMS and related federal agencies to take the necessary steps to increase access and affordability of prescription drugs that should have been included in the Draft NBPP Rule but were not.
We believe policymakers should focus on those issues that directly impact patients, such as PBM regulation and reform, standard plan designs with reasonable deductibles and nominal copays, and ensuring copay assistance counts. For example, Rhode Island still allows issuers to implement harmful copay accumulator adjustment policies that permit double-dipping by payers to take copay assistance without crediting beneficiary out-of-pocket costs.
HIV+Hep strongly supports AB 2180. It simply requires that the copay assistance which beneficiaries receive counts towards their out-of-pocket obligations. By passing this law, California will join 20 other states (Arkansas, Arizona, Colorado, Connecticut, Delaware, Georgia, Illinois, Kentucky, Louisiana, Maine, New Mexico, New York, North Carolina, Oklahoma, Oregon, Tennessee, Texas, Washington, West Virginia, and Virginia), Puerto Rico and the District of Columbia in protecting consumers by assuring their copay assistance will count towards cost-sharing obligations.