WRITTEN COMMENTS TO STATE HEALTH DEPARTMENT
(Date) (Name) (Title/Organization) (Address)
Dear (Name), It has come to my attention that the Department of Health Services is considering the addition of an HIV drug class to the Medicaid preferred drug list (PDL). I write to ask that you remove HIV drugs from consideration for the PDL because the unintended consequences of placing any kind of limitation on access to HIV medications may be significant for HIV patients and may generate costs for Medicaid that exceed potential cost savings. Today, HIV patients have the chance to live long and healthy lives provided they (1) can receive quality health care from providers knowledgeable in the treatment of their disease and (2) have access to the best medications. Without access to treatment and appropriate medications HIV patients will likely have disease progression, require expensive hospitalizations and face early death. These are serious life-threatening consequences for HIV patients and potentially costly consequences for Medicaid. Advancements in antiretroviral (ARV) treatment allow infectious disease physicians to have a continually increasing and improving collection of medications to use in the treatment of their patients. By finding the right mix of current and new HIV medications, infectious disease physicians are helping HIV patients strengthen their immune systems to fight off the infections and cancers that led to the high death rates experienced by HIV patients in the early days of the AIDS epidemic. These patients now live longer and healthier lives and have a substantially reduced need for costly health care services. Today, HIV patients need continual ARV treatment and often require medication adjustments to be successful in suppressing the replication of HIV in their body. Unfortunately, adherence to complex ARV regimens can be very difficult and failure to adhere is a significant barrier for successful treatment. One of the most significant barriers to ARV adherence is the number of pills that an HIV patient needs to take on a daily basis. Creation of the HIV class of drugs on the PDL may ultimately force patients away from highly effective single pill regimens to multi-pill regimens that will reduce adherence. Further, multi-pill regimens complicate existing barriers to adherence such as adverse drug events, ability to get prescription refills, the number of prescriptions needed by patients, and many health and psychosocial issues such as chronic mental illness, drug addiction, homelessness and poverty. Reducing adherence will diminish patient health and increase Medicaid costs. By creating a PDL for ARV drugs, DHS would be complicating important medication adherence strategies and potentially increasing Medicaid costs by impacting the ability of HIV Medicaid patients to get prescriptions filled and, when necessary, quickly accessing alternative medications to address adverse drug events and drug resistance. While prior authorization might ultimately be achieved for an ARV drug not on the POL, if a prescription or a prescription change is needed quickly and is delayed, strict adherence to
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