medicare

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Comments to CMS Administrator Oz opposing the Guarding U.S. Medicare Against Rising Drug Costs (GUARD) model

Feb 23, 2026

The HIV+Hepatitis Policy Institute strongly opposes the GUARD Model because it prioritizes projected federal savings over the health and financial stability of Medicare beneficiaries. By moving forward with a framework that acknowledges multibillion-dollar cost increases for patients and relies on a retrospective monitoring system, CMS leaves those who depend on continuous, life-sustaining treatment without meaningful protection from harm. We urge CMS to withdraw this proposal and instead pursue alternative reforms that offer immediate, point-of-sale affordability without jeopardizing treatment access, destabilizing essential safety nets, or undermining the research and development necessary to reach future therapeutic advances and cures.

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Request for Nevada governor to veto AB259 establishing maximum fair price limits for prescription drugs

Jun 11, 2025

While we support efforts to make prescription drugs more affordable, we respectfully urge you to veto Assembly Bill 259 because it would impose harmful and untested price controls without guaranteeing savings for patients. AB 259 would prohibit any entity in Nevada from purchasing or seeking reimbursement for a prescription drug at a price higher than the flawed and untested federally determined Maximum Fair Price (MFP), as established under the Inflation Reduction Act (IRA). This effectively creates a blanket price cap for all state regulated health plans, based on prices negotiated exclusively for Medicare beneficiaries.

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

Feb 10, 2023

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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Comments in support of adding HIV to Medicare medication therapy management

Feb 6, 2023

We offer our strong support of adding HIV/AIDS as one of the chronic conditions to be included in the Medicare Part D Medication Therapy Management (MTM) program. The MTM program is designed to assure, with respect to targeted beneficiaries, that covered Part D drugs are appropriately used to optimize therapeutic outcomes through improved medication use, and to reduce the risk of adverse events, including adverse drug interactions.

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