HIV Prevention

Consumer complaints with insurance coverage of PrEP in Massachusetts

We are concerned that without further Division of Insurance action, PrEP users in Massachusetts will continue to be charged cost-sharing in violation of the ACA mandate, and that those who cannot afford these copays will be in danger of PrEP discontinuation and seroconversion.  We believe that the cases we have described are but the tip of the iceberg:  only people with time, information, resources, and persistence come forward to pursue lengthy complaint processes with insurance regulators.  We should also note that insurance regulators have occasionally wrongly denied complaints, as in one of the cases highlighted by the Boston Globe.   

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Comments on Medicare NCD for PrEP using antiretroviral therapy

With deep and widening racial, ethnic, and gender disparities in uptake, access to PrEP through Medicare is of paramount importance to making sure that Medicare beneficiaries are able to benefit from the widening array of PrEP options without cost-sharing.  Medicare beneficiaries (including those dually eligible for Medicaid) comprise 10 percent of the population using PrEP, including both individuals over 65 as well as disabled individuals under 65.  We thank CMS for making clear that all FDA-approved forms of PrEP would be available without cost-sharing.  This means that Medicare beneficiaries will have unfettered access to future novel forms of PrEP immediately after FDA approval. 

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Response to request for information on improving integrity & stability of the 340B program

Given the importance of the 340B program to both HIV treatment and prevention in the United States, we are pleased that you are taking steps to improve the integrity and stability of the program. While the program has grown in recent years, we believe Congress should take steps now to ensure the 340B program works as intended and any abuses are addressed in order to ensure that the 340B program will be on solid ground and available in the future.

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House testimony on FY24 appropriations for HIV and hepatitis programs

Our nation can eliminate both HIV and viral hepatitis, but without an infusion of new resources to accelerate our efforts, we will continue to fall short of these ambitious goals. Increased investment in surveillance, education, prevention, and care and treatment will ensure we continue to address HIV and viral hepatitis, including taking a syndemic approach to achieve maximum impact. The programs and funding increases detailed below are pivotal to our nation’s ability to end both these potentially deadly infectious diseases.

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Comments on Medicare national coverage determination for long-acting injectable PrEP

On behalf of the HIV+Hepatitis Policy Institute, an organization dedicated to promoting quality and affordable healthcare for people living with or at risk of HIV, hepatitis, and other serious and chronic health conditions, we thank you for this opportunity to comment on a National Coverage Determination (NCD) by the Centers for Medicare and Medicaid Services (CMS) on the use of provider-administered pre-exposure prophylaxis (PrEP). The first provider-administered medication for HIV pre-exposure prophylaxis (Apretude or cabotegravir as PrEP) was approved by the Food and Drug Administration in January 2022. In August 2022, we wrote to you on behalf of 64 organizations to request that CMS quickly and efficiently evaluate provider-administered PrEP for a National Coverage Determination, which is the only pathway to coverage under Medicare Part B. We commend CMS on moving forward with the NCD process and urge CMS to approve the NCD for provider-administered PrEP.

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