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.
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.
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.
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.
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. Current discussions involving budget caps that reduce non-defense discretionary appropriations would have devastating impacts on our nation’s public health system and our ability to respond to these two infectious diseases.