Testimony for ad hoc HIV/AIDS interim meeting Medicaid Pharmaceutical & Therapeutics Committee Connecticut Division of Health Services
Kevin Herwig, Health Policy Director
HIV+Hepatitis Policy Institute, Washington DC
Ad hoc HIV/AIDS Interim Meeting
Medicaid Pharmaceutical & Therapeutics Committee
Connecticut Division of Health Services
My name is Kevin Herwig, Health Policy Director at the HIV+Hepatitis Policy Institute, a national advocacy organization for people affected by HIV, hepatitis, and other serious or chronic conditions. Thank you for the opportunity to submit public testimony.
Though Connecticut’s statutory exclusion of antiretrovirals from the Medicaid Preferred Drug List has ended, we continue to oppose adding any antiretrovirals for HIV treatment or prevention to the PDL with non-preferred status, which would enable prior authorization and step therapy on those drugs.
HIV treatment selection is highly individualized, based on viral resistance profiles, comorbidities, drug interactions, and tolerability. For over two decades, Connecticut protected people with HIV from utilization management on the antiretroviral drugs they need. Barriers like prior authorization cause non-medical switching and treatment interruptions, falling hardest on the lowest-income, most vulnerable people with HIV, who are seen predominantly in safety-net clinics lacking the staff time and resources to triage utilization management.
This move runs counter to the trend of federal and state protections Connecticut itself pioneered. For example, in Medicare, no prior authorization can be imposed on antiretrovirals, the lone drug class of Part D’s Six Protected Classes with this protection, in recognition of the serious harms these restrictions cause. Connecticut should not move backward from this standard.
The timing of this move is especially concerning given Medicaid community engagement requirements starting in January 2027. Without a court ruling or new CMS guidance, people with HIV who do not meet these requirements will lose Medicaid coverage, driving more churn between Connecticut’s AIDS Drug Assistance Program and Medicaid, and increasing the importance of formulary alignment between the two programs.
We also note that federal guidance bars prior authorization on all PrEP products, which must remain available without cost-sharing or utilization management.
We urge Connecticut to protect DHHS guideline-recommended medications for new starts and switches. If ARVs are added with non-preferred status, they should be older, less prescribed drugs that are not the standard of care.
We strongly urge the committee to oppose adding any ARVs to the PDL with non-preferred status and appreciate the Committee’s consideration and welcome any follow-up questions.
Kevin Herwig