Drug Pricing

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Comments to Administrator Oz on the CMS proposed rule on interoperability standards and prior authorization for drugs

Jun 15, 2026

We appreciate the opportunity to provide feedback on these proposed standards. We emphasize that technical optimization must not serve to validate or expand the current overuse of utilization management. The true measure of successful regulatory reform is a meaningful reduction in the overall volume of PAs and restrictive step therapy protocols that patients and providers face daily. We urge the administration to enforce these reduction goals firmly and to pursue swift, coordinated interagency rulemaking to expand these electronic API, timeline, and transparency protections to the millions of individuals enrolled in health plans currently excluded from this rule.

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

Jun 1, 2026

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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Medicare Drug Price Negotiation Town Hall Testimony on Biktarvy

Apr 22, 2026

The drug development pipeline is full of promise. Long-acting formulations make adherence easier; new drug classes may produce options for those with a high resistance burden or those who still struggle with side effects. Continued drug development will yield new options for an aging population with HIV and multiple comorbidities, who face high levels of stigma and discrimination and structural and social barriers to uninterrupted care. As Medicare’s HIV population is expected to double by 2035, we need continued innovation alongside continued access to current and new treatments.

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

Mar 23, 2026

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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Comments to CMS Administrator Oz opposing the Guarding U.S. Medicare Against Rising Drug Costs (GUARD) model

Feb 23, 2026

The HIV+Hepatitis Policy Institute strongly opposes the GUARD Model because it prioritizes projected federal savings over the health and financial stability of Medicare beneficiaries. By moving forward with a framework that acknowledges multibillion-dollar cost increases for patients and relies on a retrospective monitoring system, CMS leaves those who depend on continuous, life-sustaining treatment without meaningful protection from harm. We urge CMS to withdraw this proposal and instead pursue alternative reforms that offer immediate, point-of-sale affordability without jeopardizing treatment access, destabilizing essential safety nets, or undermining the research and development necessary to reach future therapeutic advances and cures.

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