Virginia Buccola, Chair
Washington State Pharmacy and Therapeutic Committee
and Drug Utilization Review Board
Washington State Health Care Authority
Re: HIV Policy
Dear Ms. Buccola:
The undersigned are members of the LGBTQ caucus of the Washington State Legislature. We are writing to ask the Washington State Pharmacy and Therapeutic Committee and Drug Utilization Review Board to ensure open access to the full range of HIV treatments for Washington State Medicaid patients. As Covid-19 continues to exact a disproportionate toll on immunocompromised and at-risk LGBTQ citizens throughout the state, the state has an opportunity to act in order to protect some of the most vulnerable and stigmatized populations in Washington.
The LGBTQ caucus seeks to ensure health equity for the LGBTQ community and is committed to ending the HIV epidemic in Washington. The state has also broadly committed to ending the HIV epidemic, with a specific goal of reducing “racial, ethnic, and other disparities in health outcomes for people living with and at risk of HIV.” Promoting open access to the latest HIV therapies for Washington State Medicaid patients is critical to achieving this stated goal.
Of course, the medical management of HIV is complex and driven by a broad range of factors, including a patient’s specific drug-resistance profile, ongoing management of other chronic diseases or conditions, the impact of side effects, and medication burden (e.g. the number of drugs taken each day and drug size).
HIV is already a protected class within the Medicare Part D program. As such, patients receiving care under this program are protected from restrictions and limitations that could hinder access to “non-preferred” therapies that may in fact be the best treatment option for a specific patient.
We believe treatment decisions should be made – and remain – between a patient and the patient’s doctor, who together can pursue use of the most appropriate therapies with due consideration given to the patient’s specific needs and unique medical profile.
In addition, the ability to rapidly start or switch to the most appropriate HIV regimen for a particular patient is critical to preserving the patient’s health and reducing overall HIV transmission. The 2019 Department of Health and Human Services Guidelines recommend that antiretroviral therapy “be started immediately or as soon as possible after diagnosis to…decrease the time required to achieve linkage to care and virologic suppression for individual patients, reduce the risk of HIV transmission, and improve the rate of virologic suppression among persons with HIV.”
Washington’s current “fail-first” policies, such as step therapy and other utilization management tactics, reflect neither the letter nor the spirit of this HHS imperative.
On top of the difficult reality of an HIV diagnosis, the barriers that current “fail-first” policies impose on vulnerable and disproportionately impacted patients can exacerbate other healthcare challenges, especially during a global pandemic for which immunocompromised populations are already at higher risk. These policies are simply not in the best interests of patients.
On behalf of Washington State’s LGBTQ community, we call on the Washington State Pharmacy and Therapeutic Committee and Drug Utilization Review Board to put an end to prior authorization, step therapy, and other utilization management tactics for HIV therapies.
State Senator, 43rd District
Speaker of the House
State Representative, 27th District
State Senator, 21st District
State Representative, 28th District
State Senator, 26th District
State Representative, 16th District
State Senator, 30th District
State Representative, 22nd District