Testimony, Comments, & Letters

FederalState

Letter asking Gov. Newsom to sign CA SB1023 to expand access to all forms of PrEP

We strongly believe that access to all forms of PrEP is essential to ending HIV in California. Nearly 5,000 Californians are diagnosed with HIV each year, and persistent disparities underscore the need to ensure access to the full range of HIV prevention options. Patients should be able to choose the PrEP option that works best for them without unnecessary insurance or administrative barriers. For these reasons, we respectfully urge you to sign Senate Bill 1023 into law.

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Comments to Sen. Cassidy on 340B Drug Pricing Integrity and Affordability for Patients Act discussion draft

We submitted comments on the 340B for Patients Act discussion draft, supporting legislative efforts to put the 340B Program on a firm statutory basis so that it can continue to serve people affected by HIV and other serious conditions far into the future. We urge Congress to protect HIV, STD, and other safety-net providers as well as ADAPs, and oppose provisions that would restrict subgrantee eligibility for STD clinics. We support an updated patient definition that does not restrict telemedicine or rapid start interventions. We also strongly support new transparency, reporting, and affordability requirements for hospitals, which account for the vast majority of 340B spending and growth but face no requirements to demonstrate patient benefit.

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Letter to PCMA on patient protections in their TrumpRx price comparisons

HIV+Hepatitis Policy Institute and the Arthritis Foundation sent a letter to PCMA raising concerns about how its members will present TrumpRx prices to insured patients. The groups urged PCMA members to clearly disclose whether TrumpRx purchases will count toward patients’ deductibles and out-of-pocket maximums, warning that a lower cash price today could ultimately result in higher costs over the course of the plan year.

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Comments to CMS on their proposed rule to codify the Medicare price negotiation program

This rulemaking is the first opportunity to codify the Negotiation Program in binding regulatory text rather than annual sub-regulatory guidance, and codification is the appropriate moment to close these gaps. Patients were promised that this program would deliver meaningful affordability and access improvements, and CMS should use this rulemaking to make good on that promise through enforceable, not merely discretionary, standards. Our comments address patient engagement in the negotiation process, transparency in how patient input is used, formulary access and utilization management protections for selected drugs, and additional concerns about the negotiation methodology itself.

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