Medicaid

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Comments urging CMS administrator Oz to withdraw the Medicaid community engagement requirement for people living with HIV

Jul 30, 2026

Our comments focus on the rule’s narrowing of the medical frailty exclusion on people living with HIV. The rule requires states not just to determine if an enrollee has a serious or chronic medical condition, but also whether that condition “significantly impairs” their ability to work. This “significant impairment” standard is inconsistent with the statute, unworkable, and would harm people with HIV and stress the safety nets they rely on. We urge CMS to withdraw the rule and reissue it so as to make it compliant with the law.

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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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Letter to all Medicaid expansion states requesting HIV exemption from community engagement requirements

May 7, 2026

People with serious and complex medical conditions or special medical needs are statutorily exempt from the community engagement requirement. Federal implementation guidance due by June is expected to provide further detail on how states may implement this exemption.  While we are seeking a federal exemption, under the law, states are allowed to define which populations qualify for the exemption.  We urge Alaska Medicaid to explicitly state that HIV is a serious and complex medical condition and that all people living with HIV (both symptomatic and asymptomatic) have special medical needs and fall under this exemption. 

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Letter to Connecticut Legislature expressing concerns with the Joint Favorable Substitute of HB 5040 and impact on HIV medications

Apr 9, 2026

We would like to express our opposition to Section 2 and concerns with Section 3 of the Joint Favorable Substitute of HB 5040. Section 2 would remove protections for antiretroviral (ARV) medications for the treatment and prevention of HIV from the imposition of prior authorization or step therapy by allowing them to be given “non-preferred” status on Connecticut’s Medicaid Preferred Drug List (PDL). These protections have been in place for over two decades. Section 3 would allow Connecticut to conduct cost-effectiveness reviews of outpatient drugs in Medicaid that could rely on discriminatory measures that devalue patients and require comparisons between U.S. drug prices and those in foreign countries.

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Comments to Colorado Dept of Health Care Policy & Financing supporting the prohibition of prior authorization for HIV treatment and prevention in Medicaid

Feb 6, 2026

We urge Colorado to maintain the prohibition of prior authorization for HIV treatment and prevention in Medicaid. Timely access to guideline-recommended HIV treatment and prevention is critical for both individual and public health. These policies align with rapid scientific advancement. Reinstating prior authorization would disproportionately harm the most vulnerable. 

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