We believe that the EHB regulations governing prescription drugs have generally been working well for patients; however, we propose some areas for improvement and are very concerned that there has been a lack of enforcement of the EHB regulations, an erosion of essential health benefits over the years, and some insurers and pharmacy benefit managers (PBMs) are devising ways to skirt the intent of the EHB law and regulations.
71 patient groups comment on the NBPP for 2024 proposed rule
We, the undersigned 71 organizations, on behalf of millions of patients and American consumers who live with complex conditions such as HIV, autoimmune diseases, cancer, diabetes, lupus, hemophilia, mental illness, hepatitis, neurological diseases, and other chronic illnesses, write to comment on the Notice of Benefits and Payment Parameters for 2024 Proposed Rule. The patients we represent appreciate all you are doing to make healthcare more accessible and affordable for beneficiaries. While there are several components of the Proposed Rule that many of us will comment on elsewhere, this letter focuses on those issues that impact access and affordability of prescription drugs.
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.)