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.
Comments on USPSTF draft research plan on PrEP
The HIV+Hepatitis Policy Institute thanks you for the opportunity to comment on the U.S. Preventive Services Task Force (USPSTF) Draft Recommendation Statement: Prevention of Human Immunodeficiency Virus (HIV) Infection: Preexposure Prophylaxis (PrEP). On October 1, 2022, HIV+Hep submitted a request, supported by 62 additional organizations, asking the USPSTF to update the existing PrEP recommendation to include long-acting injectable PrEP. We commend you for conducting and completing this timely and thorough update.
Comments on 2024 draft letter to issuers in the federally-facilitated exchanges
The HIV+Hepatitis Policy Institute commented on the 2024 Draft Letter to Issuers, praising CMS for planning to conduct adverse tiering review for HIV and hepatitis C medications but expressing disappointment that they continue to allow insurers to collecting copay assistance for drugs that is intended for beneficiaries.
Letter on MassHealth coverage of long-acting injectable PrEP
A number of Massachusetts-based providers, community-based organizations and clinical sites joined us in writing to you in August 2022 to express our concern that MassHealth had not yet added cabotegravir, a new long-acting injectable form of pre-exposure prophylaxis (PrEP) to prevent HIV, to its formulary, and to urge MassHealth to make sure it is available without any barriers to access, such as utilization management or prior authorization requirements. (A copy of the August letter is attached.)
HIV/AIDS groups letter in support of MassHealth making injectable long-acting PrEP available without barriers
HIV/AIDS groups are concerned that MassHealth (Massachusetts Medicaid) has not yet added cabotegravir, a new long-acting injectable form of pre-exposure prophylaxis (PrEP) to prevent HIV, to its formulary. We urge MassHealth to make sure injectable long-acting cabotegravir as PrEP is available on formulary without any barriers to access, such as utilization management or prior authorization requirements.