On behalf of the HIV+Hepatitis Policy Institute, we respectfully submit this testimony in support of H.1085/S.619: An Act to address barriers to HIV prevention medication. We need to ensure that everyone is able to benefit from the results of the latest scientific innovations in HIV prevention. We urge the passage of this important bill to ensure that all Bay Staters using commercial insurance can access PrEP without a financial barrier or delay.
Impact of proposed elimination of HRSA HIV PrEP funding for community health centers
As part of $767 million of domestic HIV prevention and treatment funding cuts included in the House Labor, HHS Appropriations bill is the total elimination of a program initiated by the Trump administration that is a critical component of the Ending the HIV Epidemic program. The Primary Care HIV Prevention (PCHP) program provides funding to HRSA’s community health centers in the communities most impacted by HIV to conduct activities to support and provide PrEP, which are highly effective medications that prevent HIV.
Expanding PrEP access now
In public comments to the President’s Advisory Council on HIV/AIDS, the HIV+Hepatitis Policy Institute suggests ways that the federal government can improve PrEP uptake: 1) having CMS ensure that private insurers comply with ACA $0 cost-sharing requirements, 2) having the CDC’s Division of HIV Prevention dedicate more funding for PrEP, and 3) having HRSA ensure that the community health centers PrEP program works effectively.
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.
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.