Cost-sharing

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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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Illinois testimony on PBM treatment of specialty drugs

Sep 11, 2024

I would like to highlight the direct impact of PBM actions on patients, specifically on whether they can access the drug that their provider prescribes and the cost they will pay. Much of this is carried out behind the scenes and without regulation. However, that is beginning to change with more states passing bipartisan legislation to regulate PBMs and even the very partisan Congress is working on federal legislation that will hopefully pass this year.

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Comments to MD Prescription Drug Affordability Board on HIV treatments

May 15, 2024

While we are supportive of the Maryland Prescription Drug Affordability Board (PDAB) goal of improving treatment affordability, we urge PDAB members and staff to address concerns surrounding access to provider-recommended HIV treatments at the individual level and the impact on broader public health goals and provide clarity around the affordability review process to enable meaningful community input.

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