Form Hhs-699 - Discrimination Complaint - Department Of Health And Human Services - Office For Civil Rights (Ocr) Page 11

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process,
because this coverage is not guaranteed,
and because the process of obtaining this
coverage is opaque.
Doctors choose which drugs to prescribe to their HIV patients based on a range of factors,
64
including co-occurring illnesses,
medical history and tolerance. Studies have shown the
importance of adherence in maintaining an undetectable viral load, and the greater likelihood of
65
adherence to STRs than to standard multiple pill regiments.
Therefore, it is important for
patients to have access through their insurance plans to STRs—which are pharmacologically
distinct—as well as various single-drug and combination tablets so that they and their doctors can
create optimal treatment plans.
For broad treatment purposes, it is not sufficient that one drug in a particular class may be
covered. For example, Isentress and Tivicay are both in the INSTI class. However, Tivicay is
specifically recommended to individuals who have resistance to older drugs such as Isentress and
to those who are likely to have greater adherence if they are prescribed a once-daily drug, rather
66
than a multi-dose drug such as Isentress.
An individual who is currently on Isentress and
becomes resistant must be able to switch to Tivicay, necessitating that both medications be
covered by his or her insurer, despite being in the same class.
Because compound medications are not interchangeable with their components, physicians prefer
to prescribe certain branded medications to achieve the recommended treatment regimens. For
example, physicians will seek to prescribe Triumeq, as opposed to Tivicay plus Ziagen and Epivir
or Tivicay plus Epzicom. Translating the recommended treatment regimens into their preferred
brand formulations results in the following regimens:
1. Triumeq
2. Tivicay + Truvada
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3. Genvoya
4. Stribild
5. Isentress + Truvada
6. Prezista + Norvir + Truvada
We base our cost calculations off the combination of branded medications that the majority of
physicians would describe at the best way of achieving the recommended treatment regimens.
This means prioritizing use of compound medications and STRs to minimize pill load in order to
improve adherence and positive outcomes.
                                                        
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See James L. Raper et al., Uncompensated Medical Provider Costs Associated
with Prior Authorization for Prescription Medications, 51 C
I
D
718, 720 (2010)
LINICAL
NFECTIOUS
ISEASES
(providing the amount of time, on average, health care workers spent on prior authorization in a study).
63
See Guidelines, supra note 11.
64
See id. at J-1.
65
See, e.g., S. Scott Sutton et al., Single- Versus Multiple-Tablet HIV Regimens: Adherence and Hospitalization Risk,
4 A
. J. M
C
242, 244 (206).
M
ANAGED
ARE
66
See Tivicay, P
A
, (last visited Apr. 20, 2016).
OSITIVELY
WARE
67
Genvoya was not FDA approved during the open enrollment for the 2016 QHPs. Therefore, it was not included on
formularies at the time of our assessment. It has since been added.
 
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