MassHealth Section 1115 Demonstration Amendment Request
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- Loren Gardner
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1 October 18, 2017 Eric D. Hargan Acting Secretary Department of Health and Human Services Hubert H. Humphrey Building 200 Independence Avenue, SW Washington, D.C Re: MassHealth Section 1115 Demonstration Amendment Request Dear Acting Secretary Hargan: The undersigned organizations collectively represent millions of patients who are currently battling or who have fought serious, chronic, and life-threatening diseases. We write to express our opposition to the proposal in the Massachusetts 1115 waiver amendment to potentially limit access to new and innovative drug therapies by imposing a closed formulary with as few as a single drug per therapeutic class in MassHealth, the state s Medicaid program. Prescription drugs have different indications, different mechanisms of action, and different side effects, depending on the person s diagnosis and comorbidities. Restricting MassHealth s drug benefits to a closed formulary would limit the ability of providers to make the best medical decisions for the care of their patients, effectively taking the clinical care decisions away from the doctor and patient and giving it to the state. While we appreciate that the state will, when medically necessary, maintain an exceptions process to cover drugs not included on the formulary, the proposal fails to articulate the safeguards that will be put in place to ensure enrollees have access to the prescription drugs they need. Patients suffering from chronic, life-threatening conditions need a guarantee of uninterrupted access to the prescription drugs critical to maintaining or treating their disease. Disruptions in the treatment of serious and chronic conditions, including switching a patients medication mid-treatment, could negatively impact their treatment and health outcomes. Medicaid is a crucial source of coverage for thousands of Massachusetts residents with serious and chronic health care needs. This proposed amendment could severely restrict their access to critical therapies necessary to improve health outcomes. Therefore, we strongly urge the Centers for Medicare and Medicaid Services (CMS) to reject Massachusetts 1115 demonstration amendment request in its current form. On behalf of the millions of patients we represent, we stand ready to work with you to develop policies that will ensure individuals with serious and chronic conditions maintain access to innovative and medically necessary prescription drugs. Thank you for your consideration of this important matter.
2 Sincerely, American Cancer Society Cancer Action Network 1in9 The Long Island Breast Cancer Action Coalition/Hewlett House Action CF ADAP Advocacy Association Advocates for Responsible Care ( ARxC ) AIDS Action Committee of Massachusetts AIDS Delaware Alliance for Patient Access Alpha-1 Foundation Alzheimer's & Dementia Resource Center American Academy of Dermatology Association American Academy of HIV Medicine (AAHIVM) American Association on Health and Disability American Autoimmune Related Diseases Association American Autoimmune Related Diseases Association (AARDA) American College of Rheumatology American Foundation for Women's Health / StopAfib.org American Kidney Fund American Lung Association American Medical Association American Society of Clinical Oncology Applied Pharmacy Solutions Areawide Aging Agency, Inc. Arizona Myeloma Network Arkansas Rheumatology Association Arthritis Foundation Association of Asian Pacific Community Health Organizations (AAPCHO) Association of Idaho Rheumatologists BioHouston Inc. BioNJ BionorthTX Bladder Cancer Advocacy Network (BCAN) Bonnie J. Addario Lung Cancer Foundation Brain Injury Association of Kansas and Greater Kansas City Bridge the Gap - SYNGAP1 Education and Research Foundation California Chronic Care Coalition California Rheumatology Alliance Cancer Support Community Cancer Support Community Central Ohio Cancer Support Community of Arizona CancerCare Caregiver Action Network Carrie's TOUCH Center for Health Law and Policy Innovation, Harvard Law School Center for Healthcare Innovation Central Florida Behavioral Health Network
3 Centro de Mi Salud, LLC CNY HIV Care Network Coalitions of Texans with Disabilities Colorado BioScience Association Colorado Cross-Disability Coalition Colorado Gerontological Society Community Access National Network Community Health Charities of Nebraska Community Servings, Inc. Consumers for Quality Care Cooley's Anemia Foundation Critical Mass: The Young Adult Cancer Alliance Dana Farber Cancer Institute at South Shore Medical Center Delaware Ecumenical Council on Children and Families Dia de la Mujer Latina, Inc. Diabetes Patient Advocacy Coalition Digestive Disease National Coalition Dysautonomia International Dyson and Associates, LLC Easter Seals Massachusetts Easterseals Central Texas Ecan.org EDSers United EndHepCMA Coalition Epilepsy Association of Central Florida, Inc. Epilepsy Association of the Big Bend Epilepsy Foundation Epilepsy Foundation Heart of Wisconsin Epilepsy Foundation New England Epilepsy Foundation Northwest Epilepsy Foundation of Alabama Epilepsy Foundation of Arizona Epilepsy Foundation of Connecticut Epilepsy Foundation of Delaware Epilepsy Foundation of East Tennessee Epilepsy Foundation of Greater Chicago Epilepsy Foundation of Oklahoma Epilepsy Foundation of Vermont Fight Colorectal Cancer First Step House Florida Society of Clinical Oncology FORCE: Facing Our Risk of Cancer Empowered Georgia AIDS Coalition Global Colon Cancer Association Global Healthy Living Foundation Global Liver Institute Haystack Project HealthCare Institute of New Jersey (HINJ)
4 Hep C Alliance Hispanic Health Network HIV Medicine Association Hope for Hypothalamic Hamartomas Hospice and Palliative Care Association of NY State Hospice and Palliative Nurses Association ICAN-International Cancer Advocacy Network IFAA - International Foundation for Autoimmune & Autoinflammatory Arthritis Immune Deficiency Foundation International Myeloma Foundation International Pain Foundation Iowa State Grange Kentuckiana Rheumatology Alliance Kentucky Association of Medical Oncology Kentucky Life Science Council Lakeshore Foundation Latino Commission on AIDS Long Term Care Community Coalition Lung Cancer Alliance LUNGevity Foundation Lupus And Allied Diseases Association Lupus Foundation of America Lupus Foundation of Colorado Lupus Foundation of Florida Lupus of Nevada Massachusetts Gastroenterology Association Massachusetts Pharmacists Association Massachusetts Society of Clinical Oncologists Massachusetts, Maine and New Hampshire Rheumatology Association MassEquality Mature Gay Men Aloud Medical Society of Delaware Men s Health Network Mental Health America Mental Health America of Montana Mental Health Association in New York State METAvivor Research and Support Michigan Osteopathic Association Mississippi Arthritis and Rheumatology Society Multiple Sclerosis Foundation Multiple Sclerosis Resources of CNY, Inc. NAACP New York State Conference NAMI Florida NAMI Greater Des Moines and the Iowa Mental Health Planning Council NAMI Huntington NAMI Nevada NAMI New Mexico NAMI North Dakota
5 NAMI of Central Suffolk NAMI Utah Nashville CARES NASTAD National Alliance on Mental Illness National Alliance on Mental Illness (NAMI) Texas National Association of Hepatitis C Task Forces National Association of Hepatitis Task Forces National Association of Hispanic Nurses Houston Chapter National Association of Social Workers - Texas Chapter National Association of Social Workers, North Carolina Chapter National Association of Social Workers-MA National Blood Clot Alliance National Cervical Cancer Coalition - Arizona National Coalition for Cancer Survivorship National Coalition for LGBT Health National Comprehensive Cancer Network National Consumers League National Health Council National Hemophilia Foundation National Hispanic Life Sciences Society National Infusion Center Association (NICA) National Minority Quality Forum National Organization for Rare Disorders (NORD) National Osteoporosis Foundation National Patient Advocate Foundation National Viral Hepatitis Roundtable Neuropathy Action Foundation New England Chapter American Association of Clinical Endocrinologists New Jersey Association of Mental Health and Addiction Agencies, Inc. NJ Mayors Committee on Life Sciences NMBio Ohio Association of Rheumatology Ohio Hematology Oncology Society Oregon Rheumatology Alliance Ovarian Cancer Research Fund Alliance Partnership to Improve Patient Care Prevent Blindness Children's Vision Massachusetts Project Inform Psychosocial Rehabilitation Association of New Mexico RAIN Oklahoma Rare Disease United Foundation Relapsing Polychondritis Awareness and Support Foundation Inc. Rheumatology Alliance of Louisiana Rheumatology and Internal Medicine Associates, PC Rheumatology Association of Iowa Rio Grande Valley Diabetes Association Rio Grande Valley Partnership
6 Rocky Mountain Stroke Center Rush To Live SAGE Utah Scleroderma Foundation-Rocky Mountain Chapter Sickle Cell Disease Association of Florida South Carolina Rheumatism Society South Cove Community Health Center Southeastern Wisconsin Oncology Nursing Society SURVIVEiT Survivors Cancer Action Network/Alabama Susan G. Komen Tennessee Rheumatology Society Texas Healthcare and Bioscience Institute Texas Life Sciences Collaboration Center Texas Renal Coalition TexHealth The AIDS Institute The Epilepsy Foundation of Greater Southern Illinois The Leukemia & Lymphoma Society The Myositis Association The National Adrenal Diseases Foundation The Ohio Council of Behavioral Health & Family Services Providers The Turnpike Partnership Tuberous Sclerosis Alliance U.S. Rural Health Network United Ostomy Associations of America United Partners for Human Services US Pain Foundation UsAgainstAlzheimers Utah Pride Center Wisconsin Rheumatology Association Women In Progress Inc. ZERO - The End of Prostate Cancer
Thank you for your consideration of this important matter.
October 18, 2017 Eric D. Hargan Acting Secretary Department of Health and Human Services Hubert H. Humphrey Building 200 Independence Avenue, SW Washington, D.C. 20201 Re: MassHealth Section 1115 Demonstration
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