Cost-sharing

Patient groups letter to CMS Administrator Oz Responding to the request for information on essential health benefits

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.

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Letter to Delaware Governor Meyer in Support of Preserving PrEP and PEP Access

The HIV+Hepatitis Policy Institute is a national organization promoting quality and affordable healthcare for people living with or at risk of HIV, hepatitis, and other serious and chronic health conditions. We write in strong support of House Substitute 1 for House Bill 200 and respectfully urge you to sign this critical legislation into law. This bill protects Delawareans at risk of HIV by preserving access to highly effective pre-exposure prophylaxis (PrEP) and post-exposure prophylaxis (PEP) medications and related services without cost-sharing, prior authorization, or step therapy barriers.

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Complaint letter to Mississippi insurance commissioner on Blue Cross Blue Shield of Mississippi PrEP & HIV treatment coverage Restrictions

We are submitting this formal complaint against Blue Cross Blue Shield of Mississippi (BCBSMS) regarding certain formularies offered on the individual and fully insured markets in Mississippi. First, BCBSMS is violating federal preventive health coverage requirements by covering only one of four pre-exposure prophylaxis (PrEP) medications to prevent HIV. Second, BCBSMS’ medical policy deeming long-acting injectables for the treatment of HIV “not medically necessary” does not allow for a meaningful formulary exceptions process as required by federal Essential Health Benefit (EHB) regulations.

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Comments to CCIIO on the 2027 Draft Letter to Issuers in the Federally-Facilitated Exchanges

We urge CMS to prioritize oversight of the Marketplace, which serves as an essential safety net within the country’s health insurance system and is of critical importance to people affected by HIV and other serious and chronic health conditions.  We urge CCIIO to reject proposals that decrease access to care by weakening network adequacy, time and distance, and ECP standards; enforce existing rules requiring copay assistance to count towards patient cost-sharing and that covered drugs are considered EHB; and improve the tools CMS provides to regulators to detect formulary coverage that deters enrollment by people living with HIV. As the key regulator of health insurance in the United States, we urge CCIIO to ensure that Marketplace plans provide meaningful, affordable, and non-discriminatory coverage to all. 

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