The HIV+Hepatitis Policy Institute is writing to express our concern about substandard, discriminatory coverage of HIV treatment medications by Harvard Pilgrim Health Care health plans that use its 2025 “Core 4 Tier” and “Core 5 Tier” formularies in New Hampshire. These plans do not meet the regulatory standards for formulary adequacy in CFR 156.122 (a)(3)(iii)(H) by failing to cover treatment regimens recommended in broadly accepted treatment guidelines and that are indicative of clinical best practice, thereby discouraging enrollment by people living with HIV.
Support for Oregon enhancing transparency around the use of copay accumulators, copay maximizers, and alternative funding programs
As the Oregon legislature considers modifications to SB 844, we write to express our support for proposed legislative recommendations including enhancing transparency around the use of copay accumulators, copay maximizers, and alternative funding programs. In recent years, insurers and their PBMs have implemented harmful policies that shift financial responsibilities for prescription costs to patients by not applying copayment assistance from drug manufacturers and sometimes charitable organizations.
Substandard and discriminatory HIV medication coverage and plan design by Community Health Choice Texas
We are writing to express our continuing concern about substandard, discriminatory coverage of HIV treatment medications on Community Health Choice Texas “Premier” and “Select” health insurance plans. As we have previously stated, the formularies for these plans, among other things, do not meet the regulatory standards for formulary adequacy in CFR 156.122 (a)(3)(iii)(H) by failing to cover treatment regimens specified in broadly accepted treatment guidelines and that are indicative of clinical best practice, and by discouraging enrollment by people living with HIV.
Comments to Washington Prescription Drug Affordability Board on HIV treatment and cost of care
While patients currently have access to free or affordable HIV medications through various avenues, we are concerned that setting an arbitrarily low price for these treatments could negatively impact future drug development and reduce manufacturers’ willingness to continue providing medications to millions of people in underdeveloped and underserved nations. It is essential that manufacturers have the necessary incentives to invest in research and development, enabling the creation of longer-acting treatments, preventive drugs, vaccines, and potentially even a cure for the virus. Overlooking the impact of current assistance programs on HIV treatment affordability, as well as mandating alternative drug options, disregards the nuances of HIV care and the unique requirements of each patient.
Illinois testimony on PBM treatment of specialty drugs
I would like to highlight the direct impact of PBM actions on patients, specifically on whether they can access the drug that their provider prescribes and the cost they will pay. Much of this is carried out behind the scenes and without regulation. However, that is beginning to change with more states passing bipartisan legislation to regulate PBMs and even the very partisan Congress is working on federal legislation that will hopefully pass this year.