Report: Preliminary Findings of “Hepatitis C: The State of Medicaid Access”

The National Viral Hepatitis Roundtable (NVHR) and the Center for Health Law and Policy Innovation of Harvard Law School (CHLPI) recently released the preliminary findings of Hepatitis C: The State of Medicaid Access – a comprehensive assessment of state Medicaid programs’ discriminatory restrictions on curative treatments for hepatitis C, the nation’s deadliest blood-borne disease. The full report, with accompanying rankings and state-by-state report cards, will be released in early 2017.

Preliminary analysis from the report shows some improvements in both state Medicaid program transparency and access since 2014, yet also demonstrates that most states continue to impose discriminatory restrictions which contradict guidance from the Centers for Medicare & Medicaid Services (CMS), as well as guidance from the American Association for the Study of Liver Diseases (AASLD) and the Infectious Disease Society of America (ISDA). Also concerning is that nearly half of states may not be making all restrictions publicly available. To read the preliminary findings in full, visit

“With this announcement, we are officially putting state Medicaid programs on notice,” said Ryan Clary, executive director of NVHR. “State Medicaid directors need to make all treatment criteria publicly available and detail any plans to comply with CMS guidance, which clearly states that coverage policies cannot block hepatitis C patients’ access to effective, clinically appropriate and medically necessary treatments. It is unacceptable to have discriminatory restrictions that conflict with the CMS guidance or with established hepatitis C treatment standards. Our final report will grade and rank each state’s access criteria, and states that continue to discriminate will be called out.”

The Hepatitis C: The State of Medicaid Access final report will grade and rank each state, as well as the District of Columbia, according to overall “state of access,” as determined by curative treatment restrictions related to three areas: 1) liver disease progression (fibrosis) requirements, 2) sobriety requirements, and 3) provider limitations. The report will also provide the first-ever national assessment of Medicaid Managed Care Organization (MCO) coverage of curative HCV treatments.

Key preliminary findings of the Hepatitis C: The State of Medicaid Access project include:

  • Transparency surrounding state Medicaid program hepatitis C treatment access restrictions has increased overall since 2014;
  • Access to hepatitis C treatment has improved since 2014 – primarily in the reduction/elimination of liver disease or fibrosis restrictions, while access restrictions related to sobriety and prescriber limitations have decreased to a far lesser extent; and,
  • While there are some MCOs with low levels of restrictions, many follow their states’ fee-for-service (FFS) Medicaid restrictions, while others impose more onerous restrictions in violation of federal law.

*Please note: States for which fibrosis, sobriety, and/or provider requirements remain unknown include: Alabama, Alaska, Arkansas, California, Delaware, Georgia, Indiana, Kentucky, Maine, Michigan, Mississippi, Missouri, Nebraska, Nevada, New Hampshire, New Mexico, North Carolina, South Carolina, Tennessee Utah, Washington, and Wyoming.

About Kim Rodgers

Kim Rodgers serves as a Communications Specialist at NACCHO. Her work includes promoting local health departments' best practices, as well as partner tools and resources, in infectious disease and preparedness through NACCHO's communications channels, storytelling, and outreach to various audiences.

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