Drug Pricing

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Maine letter on substandard & discriminatory HIV medication coverage & plan design by Harvard Pilgrim Health Care

Nov 8, 2024

We, the undersigned organizations and individuals, are writing to express our concern about substandard, discriminatory coverage of HIV treatment medications by Harvard Pilgrim Health Care health plans that use its 2025 “Core 5 Tier” formulary in Maine. These plans do not meet the regulatory standards for formulary adequacy in CFR 156.122 (a)(3)(iii)(H) by failing to cover treatment regimens recommended in broadly accepted treatment guidelines and that are indicative of clinical best practice, thereby discouraging enrollment by people living with HIV.[1] 

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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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Testimony on the selection of drugs for referral to MD stakeholder council

Mar 20, 2024

We believe Maryland 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. We note that the General Assembly is currently considering HB 879, legislation that would ensure that copay assistance programs will count toward deductibles and out-of-pocket maximums, and the Senate is considering SB 595.

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Comments on 2025 draft letter to issuers in the federally-facilitated exchanges

Jan 2, 2024

The HIV+Hepatitis Policy Institute submitted comments recommending that the 2025 Draft Letter to Issuers in the Federal-facilitated Exchange include a reminder to issuers that copay assistance must be counted for all but brand name drugs with a generic equivalent, plans be flagged for adverse tiering when all or a majority of drugs to treat a certain condition are on the highest tiers, CMS takes a more proactive role in enforcement action against insurers that violate the law, and CCIIO fully reviews plans for benefit designs that discriminate against certain individuals.

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Comments on the Medicare Drug Price Negotiation Program Initial Memorandum

Apr 14, 2023

Given the importance of medications to the health and well-being of people living with and at risk of HIV, people with hepatitis B & C, and their growing reliance on Medicare for prescription drugs, we are keenly interested in the implementation of the Medicare Drug Price Negotiation Program that CMS is setting up as required by the Inflation Reduction Act (IRA).

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