Public Comments for 01/21/2025 Labor and Commerce - Subcommittee #1
HB1765 - Health insurance; coverage for non-opioid prescription drugs.
Last Name: Kathy Bennett Locality: Disputanta

Please let me know about anything to do with ANY SOLAR or wind. Also why aren't you working on lowering this socialism health obamare that is failing! We pay double our house payment for healthcare. They do a certain percentage of what u make a year. I have to take money out of my 401k for healthcare that counts as income. It shouldn't count as income when you are taxing the heck out of us. We can't travel,most our prescriptions we use to take won't be covered and could go on and on about this robbery of people s hard earned money!

HB1828 - Health insurance; cost sharing for breast examinations.
Last Name: Shah Locality: Midlothian

Breast Cancer is the most commonly diagnosed cancer in the Commonwealth. Most insurance plans cover screening mammograms for women over 40 with no out-of-pocket costs under the ACA. However, screening does not provide a diagnosis. If it’s abnormal, or a patient feels a lump, they need at minimum special mammogram views and/ or an ultrasound to follow up. But there is no national law requiring health insurance to cover these diagnostic tests without cost-sharing. So some patients just don’t come back. And their cancers don’t go away-- they grow, spread, and become harder and more expensive to treat. Not everyone needs follow up testing. 10-12% of patients get called back for more testing after a screening. Less than half of those patients would need even more follow up or a biopsy. 10-15% of breast cancer is diagnosed in high-risk women. Supplemental screening with ultrasound or MRI is also not always 100% covered for women at high risk, or with dense breast tissue, despite recent guidance by the FDA, American Cancer Society, National Comprehensive Cancer Network, American College of Radiology, and the USPSTF. Some of these women can have an 80% chance of getting breast cancer in their lifetime and still forgo supplemental testing due to out of pocket costs. By a 2023 study, 1 in 5 of women would skip recommended imaging if faced with out-of-pocket costs. Another study showed that higher cost-sharing in insurance plans correlated with lower use of MRI, which actually boasts the highest cancer detection rates. This only widens the disparity gap: Black women are more likely to develop more aggressive cancers and 42% more likely to die of breast cancer than other racial or ethnic groups. These statistics are the lived experiences of real patients. As a breast radiologist serving Richmond for 17 years, and medical director of my practice, I hear too frequently missed appointments due to financial constraints. I see first-hand how these financial hurdles, especially for the underinsured or those with high-deductibles, can delay diagnosis and require treatments that in the long term far outweigh the cost of up-front imaging tests. One woman declined a diagnostic mammogram after her abnormal screening upon learning she would owe $1,500, not including the costs of any potential follow-ups. Another deferred a recommended biopsy for over a year; by then her cancer had tripled in size and spread, requiring more expensive testing and more aggressive and costly treatment. On the other hand, a 40-year-old mom received a stage 0 cancer diagnosis following additional imaging and biopsy from her 1st ever screening mammogram. Thanks to prompt follow-up testing, her prognosis was excellent, demonstrating the critical importance of accessible diagnostics. In fact I just saw her again for a checkup last month, 1 year after she was diagnosed, now cancer free and on her way out of town for the holidays. Over 20 states have passed laws like HB1828. And Virginia now has a similar law for colorectal cancer. There is a substantial body of scientific evidence that screening save lives. However, this only happens when next steps are taken to confirm a breast cancer diagnosis. Free screening but cost prohibitive diagnostics leave women in a precarious position regardless of advancements in technology or treatment. This reality exacerbates health disparities and inequities in our communities, a truth I witness daily.

Last Name: Keen Locality: Richlands

As a woman with a high risk for breast cancer in Virginia, whose daughter shares that same risk, I am asking you to please vote in favor HB 1828. I know first hand the value of early detection and prevention. As a healthcare worker who works with women who share my same risk, I have watched patients agonize about whether to pursue the recommended additional screening or pay their mortgage. I have also held a patient who did not have the financial means to pursue additional screening as she was told she had an advanced stage of breast cancer that could have been caught at a much earlier stage. Virginia is one of seventeen states with breast cancer screening laws. This is not the side of the aisle we want to be on. I understand there is a cost associated with passing this bill. There is also a much greater cost with treating late stage breast cancer that would have had much less financial burden in an earlier stage. Cost has to be a consideration when budgets are in place I understand but what is a life worth? It’s priceless. I am asking you today to stand up for the women of Virginia who face this highest risk and say I see you and you are valued. Thank you for your time and consideration of this legislation. It means more to me and my family than you could imagine.

Last Name: Shah Locality: Midlothian

Breast Cancer is the most commonly diagnosed cancer in the Commonwealth. Most insurance plans cover screening mammograms for women over 40 with no out-of-pocket costs under the ACA. However, screening does not provide a diagnosis. If it’s abnormal, or a patient feels a lump, they need at minimum special mammogram views and/ or an ultrasound to follow up. But there is no national law requiring health insurance to cover these diagnostic tests without cost-sharing. So some patients just don’t come back. And their cancers don’t go away-- they grow, spread, and become harder and more expensive to treat. Not everyone needs follow up testing. 10-12% of patients get called back for more testing after a screening. Less than half of those patients would need even more follow up or a biopsy. 10-15% of breast cancer is diagnosed in high-risk women. Supplemental screening with ultrasound or MRI is also not always 100% covered for women at high risk, or with dense breast tissue, despite recent guidance by the FDA, American Cancer Society, National Comprehensive Cancer Network, American College of Radiology, and the USPSTF. Some of these women can have an 80% chance of getting breast cancer in their lifetime and still forgo supplemental testing due to out of pocket costs. By a 2023 study, 1 in 5 of women would skip recommended imaging if faced with out-of-pocket costs. Another study showed that higher cost-sharing in insurance plans correlated with lower use of MRI, which actually boasts the highest cancer detection rates. This only widens the disparity gap: Black women are more likely to develop more aggressive cancers and 42% more likely to die of breast cancer than other racial or ethnic groups. These statistics are the lived experiences of real patients. As a breast radiologist serving Richmond for 17 years, and medical director of my practice, I hear too frequently missed appointments due to financial constraints. I see first-hand how these financial hurdles, especially for the underinsured or those with high-deductibles, can delay diagnosis and require treatments that in the long term far outweigh the cost of up-front imaging tests. One woman declined a diagnostic mammogram after her abnormal screening upon learning she would owe $1,500, not including the costs of any potential follow-ups. Another deferred a recommended biopsy for over a year; by then her cancer had tripled in size and spread, requiring more expensive testing and more aggressive and costly treatment. On the other hand, a 40-year-old mom received a stage 0 cancer diagnosis following additional imaging and biopsy from her 1st ever screening mammogram. Thanks to prompt follow-up testing, her prognosis was excellent, demonstrating the critical importance of accessible diagnostics. In fact I just saw her again for a checkup last month, 1 year after she was diagnosed, now cancer free and on her way out of town for the holidays. Over 20 states have passed laws like HB1828. And Virginia now has a similar law for colorectal cancer. There is a substantial body of scientific evidence that screening save lives. However, this only happens when next steps are taken to confirm a breast cancer diagnosis. Free screening but cost prohibitive diagnostics leave women in a precarious position regardless of advancements in technology or treatment. This reality exacerbates health disparities and inequities in our communities, a truth I witness daily.

Last Name: Kathy Bennett Locality: Disputanta

Please let me know about anything to do with ANY SOLAR or wind. Also why aren't you working on lowering this socialism health obamare that is failing! We pay double our house payment for healthcare. They do a certain percentage of what u make a year. I have to take money out of my 401k for healthcare that counts as income. It shouldn't count as income when you are taxing the heck out of us. We can't travel,most our prescriptions we use to take won't be covered and could go on and on about this robbery of people s hard earned money!

Last Name: brennan Organization: self Locality: richmond

Early detection of breast cancer made the difference between life and death for me. HB1828 will make early detection through mammograms, MRIs, ultrasounds for all women. Costs should not be a barrier to detection or treatment, and this bill is extremely important to the lives of women.

HB1923 - Health insurance; reimbursement for services rendered by certain practitioners, etc.
Last Name: Adler Organization: L487/AFL-CIO Locality: City of Richmond

The labor force is essential for continued growth and success within The Commonwealth. Worker's should be appropriately compensated with fair wages, accessible/affordable health care, safe work spaces, and financial security for their retirement. Please vote for legislation to help support hard working Virginians.

Last Name: Calvert Organization: Virginia Fire Service Board & Public Citizen Locality: Franklin County

Dear Honorable Members of the Labor and Commerce Subcommittee, I am writing to you as a member of the Governor’s Fire Services Board and a staunch advocate for the fire service in the Commonwealth of Virginia. Over the course of numerous Fire and EMS studies conducted across Virginia, I have witnessed firsthand the severe financial hardships faced by fire departments, particularly those reliant on volunteers. These challenges not only hinder their ability to operate effectively but also pose a significant risk to public safety. The Commonwealth of Virginia’s fire service, as documented in the United States Fire Administration’s 2024 National Fire Department Registry Summary, consists of 556 registered fire departments. These departments are predominantly volunteer-based, with 70.7% being fully volunteer, 16.9% mostly volunteer, 5.4% mostly career, and only 7.0% fully career. Despite the critical role these volunteer departments play, the current allocation of Aid to Localities (ATL) funding is inequitable and insufficient to meet their needs. The ATL distribution system, which allocates funds based primarily on population, disproportionately benefits jurisdictions with larger tax bases while leaving smaller, predominantly volunteer departments severely underfunded. For example, in FY 2025, Fairfax County is eligible to receive $5,666,249, and Virginia Beach $2,354,749, while smaller towns receive a minimum of $4,000 and counties no less than $10,000, per Virginia Department of Fire Programs (VDFP) policy. While this ensures a baseline, it is far from sufficient to address the actual costs faced by these departments. To illustrate: Basic personal protective firefighting gear ranges from $3,000 to $10,000 per set and must be replaced every 10 years. Self-Contained Breathing Apparatus (SCBA) systems cost $3,000 to $5,000 each. A new fire engine can range from $800,000 to $1,200,000. The reliance on bake sales, Brunswick stew events, and raffles to fund such critical needs is no longer sustainable. During the 2024 Virginia State Firefighters Association meetings, the urgency of this funding crisis was emphasized. When I asked members when we should sound the alarm that the Commonwealth is in an emergency situation regarding the volunteer fire service, the unanimous response was, “Now!” The National Volunteer Fire Council highlights that departments are struggling to recruit and retain members due to increased demands on time, training requirements, and societal changes, such as the prevalence of two-income households. Without significant investment in recruitment and retention incentives for the volunteer fire service, the Commonwealth will face the monumental challenge of replacing 70.7% of its firefighting workforce with paid personnel—an outcome that would impose substantial financial burdens on local governments and taxpayers. I respectfully urge the subcommittee to take immediate action to increase ATL funding and revamp the current distribution system to ensure equitable and adequate support for all fire departments, especially those serving rural and volunteer-reliant communities. Addressing this issue now will help avert a crisis and ensure the safety and resilience of our communities. Thank you for your attention to this critical matter. I am available to discuss this issue further and provide additional insights based on my experiences. Sincerely, Dr. James Alan Calvert

HB1942 - Financial institutions; regulation of money transmitters, penalty, effective date.
Last Name: Yates Organization: Electronic Transactions Association Locality: Arlington

Comments Document

On behalf of the Electronic Transactions Association (“ETA”), the leading trade association for the payments industry, we appreciate the opportunity to provide the comments below in strong support of HB 1942 related to adopting money transmission modernization standardization for the state of Virginia. ETA strongly supports the passage of HB 1942 which incorporates the Conference of State Bank Supervisors (“CSBS”) Model Money Transmission Modernization Act (“Money Transmitter Model Law”) into Virginia law. We commend the work of CSBS in bringing together regulators and other stakeholders to develop a uniform, nationwide framework for the regulation of money transmission businesses.

HB1956 - Provider contracts; pharmacies allowed to refuse to fill certain prescriptions.
Last Name: Smiley Organization: Virginia Food Industry Association Locality: Richmond

VFIA supports HB 1956.

Last Name: Crawford Locality: Mechanicsville

SUPPORT I am writing in support of this bill as a Virginia-based hospital pharmacist with 14 years of experience. Pharmacy benefit managers (PBMs) are making it more difficult for patients to receive life-saving medications for their own profit. This bill would allow patients to choose where they could receive their important medications, whether it be at their physician's office, in a medication infusion center, or from their PBM's specialty pharmacy. Right now PBMs dictate where patients may receive their medications. In a state that protects an individual's right to choose where they get their car fixed following a collision, I feel we should extend the same protection to patients who are receiving infusion medications.

Last Name: Kathy Bennett Locality: Disputanta

Please let me know about anything to do with ANY SOLAR or wind. Also why aren't you working on lowering this socialism health obamare that is failing! We pay double our house payment for healthcare. They do a certain percentage of what u make a year. I have to take money out of my 401k for healthcare that counts as income. It shouldn't count as income when you are taxing the heck out of us. We can't travel,most our prescriptions we use to take won't be covered and could go on and on about this robbery of people s hard earned money!

HB2069 - Insurance; additional purposes for Fire Programs Fund Aid to Localities Grant Program established.
Last Name: Rotunno Organization: National Association of Mutual Insurance Companies Locality: Washington, D.C.

Comments Document

NAMIC letter in opposition to House Bill 2069.

Last Name: Harris Organization: Virginia State Firefighter's Association Locality: Lunenburg County

The Virginia State Firefighter's Association strongly supports this bill. It is vital to the citizens of Virginia that fire departments need to upgrade and replace fire equipment as well as to employ additional firefighters. This has become a crisis in our Commonwealth and many fire departments will be going broke and will be unable to answer fire calls in many communities. The traditional fund raising efforts by the smaller fire departments no longer work as the cost of fire equipment has gone up so far and fast that enough money can not be raised even if you have a fund raising event every week. Please pass this bill in order to further protect our citizens and our property in the state. Thank you.

Last Name: Harris Organization: Virginia State Firefighter's Association Locality: Lunenburg County

The citizens in the Commonwealth of Virginia are becoming more vulnerable from fire because many fire departments here in Virginia lack the manpower as well as the equipment to fight fire. The prices of the equipment has gone thru the roof and many departments can't raise enough funds to operate on much less to have any left over for equipment purchases. The smaller localities do not have any funds left over from their budget because the schools, police and other services are so expensive money just doesn't go far enough to be able to help the fire departments with their budget. This is becoming a very serious problem here in Virginia and it is only a matter of time before deaths from fires will increase or we have major forest fires or commercial or industrial fires like they are experienceing in Californa. Fire departments loose members every year because of the time needed away from their families just to raise funds for the fire department. You can't have enough bingo, bake sales, golf tournaments or you name it

Last Name: mongold Organization: New Market Fire and Rescue Inc Locality: New market

Good morning, I am the volunteer Chief and Town appointed Chief for New Market Fire and Rescue Inc. I am writing this in favor of HB 2069. Our organization just completed a $730 000.00 renovation of our living quarters and office area. This was too improve the female bumk room and male bunkroom areas and too create separate locker facilities. Also we upgraded our office area for our volunteers and career staff. We depend on our fundraising efforts to support our endeavors. This bill would allow us to seek funding for such a project or future projects. This would help relieve some of the pressures volunteers face in their fundraising efforts. This would also help local governments and made the burden on them and taxes that these small localities face. I ask that you support this bill as it supports your small local first responders.

Last Name: Stitt Organization: Barren Springs Vol. Fire Department and the Southwest Virginia Firefighters Association Locality: Wythe County

I am writing in favor of HB 2069. In many localities of Southwest Virginia, the Aid to Locality Funding is the majority of departments operating budgets. The increase cost of equipment and training has grown exponentially over the years. With out these increases many departments will struggle to maintain adequate equipment to meet vastly changing needs of today's fire service. The dangers we face today have never been contemplated in previous years. The introduction of lithium-ion batteries and electric vehicles affect us all and require new techniques, equipment, and training. This is a field that will continue to grow and change. The fire service must adapt with that change which unfortunately all equates to adequate funding. I am a firm believer that governments primary function is to provide for the safety of its citizens. I ask that you stand with the firefighters of Southwest Virginia and provide the financial aid they require to adequately protect our communities. Respectfully, Chief Joshua Stitt Barren Springs Volunteer Fire Department President of the Southwest Virginia Firefighters Association

Last Name: Ferguson Locality: Botetourt County

I am writing to express support for HB2069, Insurance; Fire Programs Fund; purposes; Aid to Localities Grant Program as this legislation is essential to furthering the necessary funding and support for fire departments across the Commonwealth. More specifically, facilities, mental health resources for firefighters, hiring of fire personnel and recruitment and retention programs. The fire service is Virginia is in significant need of additional funding to support the abilities of fire departments to prepare for and respond to the needs of their communities. The areas of focus mentioned are extremely important to the viability of localities such as ours to evolve to meet the demands of our community. Many Virginia communities are struggling with the funding for investing in personnel as the volunteer workforce continues to decline. Additionally, funding for the building, renovating, or expansion of facilities is critical for fire departments all across the Commonwealth. The expense with sustaining these vital facilities is often times very difficult for local governments to afford for. In closing, I ask that you please seriously consider supporting this initiative to further ensure the solidarity of Virginia's fire service for the betterment of the entire Commonwealth.

Last Name: Duck Organization: Carrsville Fire & Rescue Locality: Isle of Wight

Thank you for considering this important legislation to provide more funding for fire services. As a volunteer and an insurance agent, I speak in support of the legislation. The insurance industry will talk about additional expenses for them. This is not true. They will pass this on to the consumer. Remember, in the last 3 years, the insurance industry has had no problem increasing consumer rates an average of 30% over the last 3 years. This 1% change will not hurt the consumer. It will help them. Please vote to increase funding and make sure the volunteer agencies are supported as well as the counties, towns and cities.

Last Name: Grimsley Organization: Individual Locality: Culpeper county

Please support this bill.

Last Name: Bailey Organization: Virginia State Firefighters Association Locality: Charlotte County

As President of Virginia State Firefighters Association and a volunteer chief for over 40 years I’ve seen the needs first hand of Virginia’s Fire Departments. We are facing the perfect storm, our membership has dramatically declined while the cost to do business has risen 104% in 5 years. The study from HB 2175 and validated by VCU this year shows Virginia’s Fire Service is in a crisis. In addition we’re facing looming mandates from OSHA that will further cripple our existence. If financial assistance doesn’t come soon from the state I fear many departments across the state simply will be unable to continue service. This will put many of Virginia’s citizens in pearl. Your departments do much more than fire suppression, in fact that is only a small percentage of what we do. Emergency Medical Services accounts for a majority of our calls. Approximately 59% of EMS patients are transported by fire departments. Search & Rescue, HAZMAT calls, down wires & trees blocking roads, animal rescue and the list goes on we are the one stop shop for almost all 911 calls. The burden that is placed on communities across Virginia to fund departments is not sustainable. Please help us protect Virginia families !

Last Name: Logan Organization: Fort Lewis Volunteer Fire Department Locality: Roanoke County

The Fire Progams fund is a vital program to support and provide firefighter training and equipment upgrades and has not been increased in many. many, many years. It's the only program that supports the fire service in Virginia. There has been a need to increase this for a long time as costs of everything have increased tremendously over the years and funding has not kept pace. We at Fort Lewis Volunteer Fire Department request your assistance in passing this bill to support all state firefighters. Thank You

Last Name: Flippo Organization: Aldie Volunteer Fire Department Locality: Loudoun County

Please give consideration to increasing the aid to localities fund for fire departments in Virginia. Expenses have become overwhelming and we need the additional funding to meet our basic needs. Thank You. Jeff Flippo, Vice President Aldie Volunteer Fire Department Aldie, Virginia

HB2073 - Financial institutions; discrimination prohibited, penalty.
No Comments Available
HB2083 - Pregnant qualified individuals; Va. Health Benefit Exchange to establish special enrollment period.
Last Name: Calvert Organization: Virginia Fire Service Board & Public Citizen Locality: Franklin County

Dear Honorable Members of the Labor and Commerce Subcommittee, I am writing to you as a member of the Governor’s Fire Services Board and a staunch advocate for the fire service in the Commonwealth of Virginia. Over the course of numerous Fire and EMS studies conducted across Virginia, I have witnessed firsthand the severe financial hardships faced by fire departments, particularly those reliant on volunteers. These challenges not only hinder their ability to operate effectively but also pose a significant risk to public safety. The Commonwealth of Virginia’s fire service, as documented in the United States Fire Administration’s 2024 National Fire Department Registry Summary, consists of 556 registered fire departments. These departments are predominantly volunteer-based, with 70.7% being fully volunteer, 16.9% mostly volunteer, 5.4% mostly career, and only 7.0% fully career. Despite the critical role these volunteer departments play, the current allocation of Aid to Localities (ATL) funding is inequitable and insufficient to meet their needs. The ATL distribution system, which allocates funds based primarily on population, disproportionately benefits jurisdictions with larger tax bases while leaving smaller, predominantly volunteer departments severely underfunded. For example, in FY 2025, Fairfax County is eligible to receive $5,666,249, and Virginia Beach $2,354,749, while smaller towns receive a minimum of $4,000 and counties no less than $10,000, per Virginia Department of Fire Programs (VDFP) policy. While this ensures a baseline, it is far from sufficient to address the actual costs faced by these departments. To illustrate: Basic personal protective firefighting gear ranges from $3,000 to $10,000 per set and must be replaced every 10 years. Self-Contained Breathing Apparatus (SCBA) systems cost $3,000 to $5,000 each. A new fire engine can range from $800,000 to $1,200,000. The reliance on bake sales, Brunswick stew events, and raffles to fund such critical needs is no longer sustainable. During the 2024 Virginia State Firefighters Association meetings, the urgency of this funding crisis was emphasized. When I asked members when we should sound the alarm that the Commonwealth is in an emergency situation regarding the volunteer fire service, the unanimous response was, “Now!” The National Volunteer Fire Council highlights that departments are struggling to recruit and retain members due to increased demands on time, training requirements, and societal changes, such as the prevalence of two-income households. Without significant investment in recruitment and retention incentives for the volunteer fire service, the Commonwealth will face the monumental challenge of replacing 70.7% of its firefighting workforce with paid personnel—an outcome that would impose substantial financial burdens on local governments and taxpayers. I respectfully urge the subcommittee to take immediate action to increase ATL funding and revamp the current distribution system to ensure equitable and adequate support for all fire departments, especially those serving rural and volunteer-reliant communities. Addressing this issue now will help avert a crisis and ensure the safety and resilience of our communities. Thank you for your attention to this critical matter. I am available to discuss this issue further and provide additional insights based on my experiences. Sincerely, Dr. James Alan Calvert

HB2097 - Health insurance; coverage requirements for prostate cancer screenings.
Last Name: John D. Glass Locality: Ruckersville

Dear Members of the House Labor and Commerce Committee, I support HB2097, sponsored by Del Terry Austin, to eliminate PSA screening costs for High Risk men. In 2002, at the age of 55, my doctor had me take a PSA test. I had no idea what a PSA test was but was told it was 4.0 and I should find a urologist. Because I was able to pay for my copay, my prostate cancer was detected. I eventually entered the Watchful Waiting program at Johns Hopkins in 2003, and had my prostate removed in January 2006. I am, and have been cancer free ever since because I was able to obtain a PS A screening. Please support this important bill. Thank you, John Glass Ruckersville, VA

Last Name: Alison Manson Organization: ZERO Prostate Cancer Locality: Alexandria

Comments Document

Our written testimony is attached. Please vote for HB 2097 to reduce the number of Virginia families who lose precious time to prostate cancer - and to ensure that every Virginian has access to the care they need to stay healthy. Thank you, and please follow up with me with any questions.

Last Name: Moon Locality: Richmond

Comments Document

My name is Peter Moon PhD, VCU Professor Emeritus, 31 year Prostate Cancer survivor with PCa and 22 year support group leader of RVa Us Too Prostate Cancer Support Group/Zero Cancer (rvacancersupport.org), and I’m writing to testify in support of HB 2097 by Del. Austin.

Last Name: Lanton Organization: American Association of Clinical Urologists Inc. (AACU) Locality: Washington D.C.

Comments Document

My name is Ron Lanton and I am the Government Affairs Director for the American Association of Clinical Urologists Inc. (AACU). We are attaching our comments in support of HB2097.

HB2099 - Health insurance; required provisions regarding prior authorization for health care services.
Last Name: Georgia Bates Organization: ZERO Prostate Cancer Locality: Alexandria, VA

Comments Document

Dear Chair Ward and Members of the House Labor and Commerce Committee, I’m writing in support of HB 2099 on behalf of ZERO Prostate Cancer, the leading national nonprofit with the mission to end prostate cancer and help all those who are impacted, and on behalf of the patients and patient advocates we represent. Although prior authorization is considered a utilization management tool, 86% of physicians reported that prior authorizations led to waste rather than the cost savings claimed by insurers. 93% of oncologists surveyed reported that prior authorization delayed life-saving treatments for their patients, according to a 2019 American Society for Radiation Oncology survey. A 2023 American Medical Association survey found that 94% of respondents reported treatment delays to prior authorization, and research suggests delays disproportionately impact those at-risk for prostate cancer, including Black patients and patients with lower incomes. Over 200 state bills were introduced last year to make needed reforms to prior authorization requirements for procedures, tests, treatment, and prescriptions. To ensure patients have timely access to medically necessary care, ZERO Prostate Cancer recommends swift passage of this bill and further efforts to reform prior authorization. Please follow up with georgia@zerocancer.org with any questions.

Last Name: Lanford Organization: Association for Clinical Oncology Locality: Alexandria

Comments Document

Dear Chair Ward and Members of the House Labor and Commerce Committee, On behalf of the Virginia Association of Hematologists and Oncologists (VAHO) and the Association for Clinical Oncology (ASCO), I'm pleased to submit the attached letter in support of HB 299, which would streamline prior authorization practices in Virginia. Please let me know if you have any questions about cancer care - we're happy to be a resource. Best, Sarah Lanford

Last Name: Kathy Bennett Locality: Disputanta

Please let me know about anything to do with ANY SOLAR or wind. Also why aren't you working on lowering this socialism health obamare that is failing! We pay double our house payment for healthcare. They do a certain percentage of what u make a year. I have to take money out of my 401k for healthcare that counts as income. It shouldn't count as income when you are taxing the heck out of us. We can't travel,most our prescriptions we use to take won't be covered and could go on and on about this robbery of people s hard earned money!

HB2100 - Medicare supplement policies; annual open enrollment period, individual Medicare policies, etc.
Last Name: Silverman Organization: VA Chapter of Physicians for a National Health Plan Locality: Manakin Sabot

Due to the confusing landscape of choosing a Medicare Supplement, recipients should be able to change their carrier or plan without penalty of medical insurance underwriting. Some plans, Plan C and Plan F, are being phased out and therefore the population of these plan participants will be getting older and therefore more expensive. The individuals should be able to choose a new plan as their plans may soon become cost prohibitive. Among individual lettered plans there are many carriers with a wide range of premiums. This changes annually and everyone should be able to choose the lowest premium available in their area without underwriting of their pre-existing conditions. This would encourage a more competitive market and better service. At age 65, I chose Anthem because my agent said it was the largest carrier in VA and therefore, they would be able to keep premium increases low. Unfortunately, this has not held true and now there are numerous plans that have lower premiums that I would like to avail myself of. Presently because we cannot switch, there is no pressure to keep prices low. Doug Gray from the insurance industry stated in his Senate testimony that insurance brokers, which his plans pay commissions, would be unlikely to provide honest recommendations to Medicare recipients in reference to the hazards of switching policies. So why should we believe him that this would adversely affect insurance premiums when the difference in overall expenditures between the different carriers or plans is marginal at best. Here in VA, most Medicare recipients choose the broadest coverage. 43.5% are enrolled in Plan F which is no longer available, 42.4% in Plan G, 7.2 % in Plan N and all the lesser plans make up less than 7%. So, seniors are not going to give up their broad coverage unnecessarily. They just want to get the lowest premium for their healthcare services. Many states have loosened restrictions on allowing Medicare recipients to switch plans and carriers with open enrollment and guaranteed issue under a variety of circumstances. 29 states allow recipients to change when they lose retirement benefits, 10 states when they lose Medicaid eligibility, and 12 allow guarantee issue rights for current Medigap policyholders like myself. And 4 states allow either continuous or annual guaranteed issue rights for all including Medicare Advantage members. The cost of premiums has not shown a relationship between the loosening of these restrictions among the various states that have passed these more consumer-friendly policies. Matter of fact some of these states now have premiums that are lower than we have here in Virginia. Let’s remember these plans cover every physician and hospital in the United States. Each lettered plan covers the same exact services no matter which carrier you choose without prior authorization. Thank you.

Last Name: Jack Organization: ALS Association Locality: Leesburg

Comments Document

January 30, 2025 Delegate Jeion Ward Chair, Labor and Commerce Committee The Honorable Chair Ward, Vice Chair Herring and Members of the Labor and Commerce Committee: RE: HB 2100 -- Medicare supplement policies; annual open enrollment period Position: SUPPORT My name is Lindsay Jack, and I am the Managing Director of Advocacy at the ALS Association. I am writing today in support of HB 2100, Medicare supplement policies, annual open enrollment period. ALS is a fatal progressive neurodegenerative disease that that affects nerve cells in the brain and spinal cord, it slowly robs a person’s ability to walk, talk, eat, and eventually breathe. There is no cure for ALS (also commonly known as Lou Gehrig’s disease), every diagnosis is lethal. Every 90 minutes, someone is diagnosed with the disease, and someone passes away from it. HB 2100 would make Medicare supplemental insurance policies, known as “Medigap,” more accessible and affordable for people living with ALS. Medigap plans, sold by private companies, are intended to cover gaps in Medicare coverage, such as copayments, deductibles, and other healthcare costs. Virginia would join 12 other states to provide a once a year 60-day guaranteed access open enrollment window for current Medigap plan enrollees who wish to switch insurance carriers, but not their Medigap plan, to an insurance carrier offering a more affordable premium. The bill offers what is commonly called a “birthday rule” offering an additional annual open enrollment period commencing on the day of the individual’s birthday. This bill allows Medigap enrollees to switch the insurance carrier of their Medigap plan, but not switch their plan itself (i.e., someone could go from an Wellcare Plan A to an Anthem Plan A, but could not switch from a Wellcare Plan A to an Anthem Plan G). This provides enrollees with an option to change insurers to make sure premiums fit their financial circumstances while not allowing an enrollee to change their level of coverage. If an insurer has increased premiums to the point where enrollees are struggling to make premium payments, shouldn’t they be allowed to switch to another insurance carrier that offers lower premiums for the same Medigap plan without being medically underwritten? The 12 other states that have passed similar laws have dozens of insurers offering hundreds of Medigap plans in their states. Given the number of insurers offering hundreds of Medigap plans, one can reliably conclude that the Medigap insurance markets in states which have already passed laws like HB 2100 are an apparent success. For all these reasons, I respectfully request your support for HB 2100. Please contact me if you have any questions. Sincerely, Lindsay Jack Lindsay Jack Managing Director, Advocacy The ALS Association Lindsay.Jack@als.org

Last Name: Greenberg Locality: Glen Allen

Support bill

Last Name: Olson Locality: Alexandria

Seniors should be able to freely change health plans based on their own health and budget, not denied for needing more coverage or having pre-existing conditions (when switching to Medicare from Medicare Advantage). This bill needs to apply to all Medicare recipients, including those switching from Medicare Advantage. Using the regular Medicare open enrollment period (Oct-Dec) is less confusing than using individual birthdays to permit supplemental policy changes. Please amend. We can do better for our seniors. Thank you.

Last Name: Gruber Locality: Arlington

This proposed “birthday bill” allowing Medigap subscribers to change plans in the month after their birthday may be quite beneficial to the health insurance industry, but doesn’t go nearly far enough ro protect Medicare recipients who missed the initial Medigap enrollment window or are trying to switch to traditional Medicare from a Medicare Advantage plan. I am calling on the committee to amend this bill so that it includes the following provisions: 1. Require Medicare supplement issuers to provide guaranteed issue rights for all Medicare recipients – without medical underwriting – during the annual Medicare open enrollment period (October 15 - December 7); 2. Allow enrollees to upgrade Medigap coverage to meet their future health needs, rather than limiting their choice only to Medigap plans with “equal or lesser coverage” to their current Medigap coverage during this open enrollment period; 3. Ensure that ALL Medicare recipients have guaranteed issue enrollment in a Medigap plan, including those transitioning from Medicare Advantage to traditional Medicare; and 4. Prohibit Medicare supplement issuers from imposing waiting periods, imposing higher premiums, or denying coverage to Medicare recipients based on age, pre-existing conditions, or disability. Virginia legislators have the opportunity to stand up for vulnerable seniors and disabled individuals in their communities against the powerful health insurance lobby. I hope you will also have the courage to do so.

Last Name: Silverman Organization: VA Chapter of PNHP Locality: Manakin Sabot

Due to the confusing landscape of choosing a Medicare Supplement, recipients should be able to change their carrier or plan without penalty of medical insurance underwriting. Some plans, Plan C and Plan F, are being phased out and therefore the population of these plan participants will be getting older and therefore more expensive. The individuals should be able to choose a new plan as their plans may soon become cost prohibitive. Among individual lettered plans there are many carriers with a wide range of premiums. This changes annually and everyone should be able to choose the lowest premium available in their area without underwriting of their pre-existing conditions. This would encourage a more competitive market and better service. At age 65, I chose Anthem because my agent said it was the largest carrier in VA and therefore, they would be able to keep premium increases low. Unfortunately, this has not held true and now there are numerous plans that have lower premiums that I would like to avail myself of. Presently because we cannot switch, there is no pressure to keep prices low. Doug Gray from the insurance industry stated in his Senate testimony that insurance brokers, which his plans pay commissions, would be unlikely to provide honest recommendations to Medicare recipients in reference to the hazards of switching policies. So why should we believe him that this would adversely affect insurance premiums when the difference in overall expenditures between the different carriers or plans is marginal at best. Here in VA, most Medicare recipients choose the broadest coverage. 43.5% are enrolled in Plan F which is no longer available, 42.4% in Plan G, 7.2 % in Plan N and all the lesser plans make up less than 7%. So, seniors are not going to give up their broad coverage unnecessarily. They just want to get the lowest premium for their healthcare services. Many states have loosened restrictions on allowing Medicare recipients to switch plans and carriers with open enrollment and guaranteed issue under a variety of circumstances. 29 states allow recipients to change when they lose retirement benefits, 10 states when they lose Medicaid eligibility, and 12 allow guarantee issue rights for current Medigap policyholders let myself. And 4 states allow either continuous or annual guaranteed issue rights for all including Medicare Advantage members. The cost of premiums has not shown a relationship between the loosening of these restrictions among the various states that have passed these more consumer-friendly policies. Matter of fact some of these states now have premiums that are lower than we have here in Virginia. Let’s remember these plans cover every physician and hospital in the United States. Each lettered plan covers the same exact services no matter which carrier you choose without prior authorization. Thank you.

Last Name: Brock Locality: Fredericksburg

I am certain we all agree that the healthcare of your constituents is the most important consideration when it comes to health insurance. And that is exactly the issue before this Committee. I thus strongly recommend amending HB2100 to allow all Medicare enrollees the maximum choice to alternate between any Medicare plan without penalty; and I urge you to put the healthcare of Virginians first by supporting the amended bill. Thank you. Jay D. Brock, MD Fredericksburg 1/21/2025 Former Assistant Professor Faculty of Medicine Department of Family Medicine McGill University Montreal, Canada Past President Fredericksburg Area Medical Society Fredericksburg, Va

Last Name: Calvert Organization: Virginia Fire Service Board & Public Citizen Locality: Franklin County

Dear Honorable Members of the Labor and Commerce Subcommittee, I am writing to you as a member of the Governor’s Fire Services Board and a staunch advocate for the fire service in the Commonwealth of Virginia. Over the course of numerous Fire and EMS studies conducted across Virginia, I have witnessed firsthand the severe financial hardships faced by fire departments, particularly those reliant on volunteers. These challenges not only hinder their ability to operate effectively but also pose a significant risk to public safety. The Commonwealth of Virginia’s fire service, as documented in the United States Fire Administration’s 2024 National Fire Department Registry Summary, consists of 556 registered fire departments. These departments are predominantly volunteer-based, with 70.7% being fully volunteer, 16.9% mostly volunteer, 5.4% mostly career, and only 7.0% fully career. Despite the critical role these volunteer departments play, the current allocation of Aid to Localities (ATL) funding is inequitable and insufficient to meet their needs. The ATL distribution system, which allocates funds based primarily on population, disproportionately benefits jurisdictions with larger tax bases while leaving smaller, predominantly volunteer departments severely underfunded. For example, in FY 2025, Fairfax County is eligible to receive $5,666,249, and Virginia Beach $2,354,749, while smaller towns receive a minimum of $4,000 and counties no less than $10,000, per Virginia Department of Fire Programs (VDFP) policy. While this ensures a baseline, it is far from sufficient to address the actual costs faced by these departments. To illustrate: Basic personal protective firefighting gear ranges from $3,000 to $10,000 per set and must be replaced every 10 years. Self-Contained Breathing Apparatus (SCBA) systems cost $3,000 to $5,000 each. A new fire engine can range from $800,000 to $1,200,000. The reliance on bake sales, Brunswick stew events, and raffles to fund such critical needs is no longer sustainable. During the 2024 Virginia State Firefighters Association meetings, the urgency of this funding crisis was emphasized. When I asked members when we should sound the alarm that the Commonwealth is in an emergency situation regarding the volunteer fire service, the unanimous response was, “Now!” The National Volunteer Fire Council highlights that departments are struggling to recruit and retain members due to increased demands on time, training requirements, and societal changes, such as the prevalence of two-income households. Without significant investment in recruitment and retention incentives for the volunteer fire service, the Commonwealth will face the monumental challenge of replacing 70.7% of its firefighting workforce with paid personnel—an outcome that would impose substantial financial burdens on local governments and taxpayers. I respectfully urge the subcommittee to take immediate action to increase ATL funding and revamp the current distribution system to ensure equitable and adequate support for all fire departments, especially those serving rural and volunteer-reliant communities. Addressing this issue now will help avert a crisis and ensure the safety and resilience of our communities. Thank you for your attention to this critical matter. I am available to discuss this issue further and provide additional insights based on my experiences. Sincerely, Dr. James Alan Calvert

Last Name: Silverman Organization: VA Chapter of PNHP Locality: Manakin Sabot

Comments Document

Due to the confusing landscape of choosing a Medicare Supplement, recipients should be able to change their carrier or plan without penalty of medical insurance underwriting. Some plans, Plan C and Plan F, are being phased out and therefore the population of these plan participants will be getting older and therefore more expensive. The individuals should be able to choose a new plan as their plans may soon become cost prohibitive. Also as people get older they may not need to have the Foreign Travel Emergency coverage and could then choose a plan with lower premiums. Among individual lettered plans there are many carriers with a wide range of premiums. This changes annually and everyone should be able to choose the lowest premium available in their area without underwriting of their pre-existing conditions. This would encourage a more competitive market and better service. Presently because we cannot switch, there is no pressure to keep prices low. Doug Gray from the insurance industry stated in his Senate testimony that insurance brokers would be unlikely to provide honest recommendations to Medicare recipients in reference to the hazards of switching policies. So why should we believe him that this would adversely affect insurance premiums when the difference in overall expenditures between the different carriers or plans is marginal at best.

Last Name: Kathy Bennett Locality: Disputanta

Please let me know about anything to do with ANY SOLAR or wind. Also why aren't you working on lowering this socialism health obamare that is failing! We pay double our house payment for healthcare. They do a certain percentage of what u make a year. I have to take money out of my 401k for healthcare that counts as income. It shouldn't count as income when you are taxing the heck out of us. We can't travel,most our prescriptions we use to take won't be covered and could go on and on about this robbery of people s hard earned money!

HB2106 - Health insurance; prohibits pharmacy override for enrollee with sickle cell disease.
No Comments Available
HB2107 - Health insurance; pharmacies, freedom of choice, delivery of prescription drugs, penalties.
Last Name: Memphis Organization: Healthcare Distribution Alliance (HDA) Locality: Washington DC

On behalf of the Healthcare Distribution Alliance (HDA), representing the nation’s primary healthcare distributors, I am writing to offer support of HB 2107. If successfully enacted, this legislation would limit the ability of certain entities (Payers) to engage in the growing practice of “white bagging” which has the potential to disrupt patient care and is increasingly being required by insurers and pharmacy benefit managers (PBMs). HDA’s distributor members serve as the critical logistics provider within the healthcare supply chain, adding efficiency, security and keeping the healthcare system functioning every day. HDA members work 24 hours a day, 365 days a year to ensure approximately 10 million healthcare products per-day, including specialty drugs, are safely and securely delivered to more than 330,000 providers across the country. In Virginia, our members serve over 5,800 sites of care. As referenced above, the practice of “white bagging” is an arrangement between insurance companies and designated specialty pharmacies that they contract with, or own themselves, to ship physician-administered medications directly to sites of care (i.e., hospitals, clinics, doctors’ offices) after they have been prescribed by the attending physician. Most U.S. hospitals and physician offices maintain inventories of medications their patients need which can be immediately available when the patient arrives for treatment based on that patient’s real-time needs. When a patient’s insurance provider interjects and stipulates the drug prescribed by their attending physician and available at the site of care must instead be dispensed and shipped from an off-site specialty pharmacy, this practice has the potential to delay access to treatments. HB 2107 will remedy the aforementioned barriers to care. While delaying treatment is burdensome on the patient as well as the physician providing care, white bagging practices introduce additional concerns as well. Such concerns include ensuring the proper storage and handling of these products which in turn may increase provider liability. The creation of increased drug waste due to the product being specified for a specific beneficiary. Most notably for many patients, the process of “white bagging” may increase costs to the patient as well due to treatment typically being switched from a patient’s medical benefit to his/her pharmacy benefit which often includes higher cost-sharing responsibilities. Complex drug therapies for rare diseases require timely access and enhanced physician oversight of storage, dosing, and administration. Patients trust their doctors to care for them. HDA supports HB 2107.

Last Name: Roberts Organization: Remington Drug company Locality: Remington, Va

I am a pharmacist and an owner of a community pharmacy in southern Fauquier County. While the testimony on this bill ( HB2107) zeroed in on oncology/specialty medications, the retail setting is also challenged by this burden, namely lack of choice when selecting a pharmacy to provide care. Just today (01/21/2025) a patient arrived at our pharmacy to pick up his medication for atrial fibrillation, a life threating event. In December 2024 and previously his copay was $50.00. Today (01/21/2025) his copay was in excess of $540.00. Following a call to the PBM helpdesk, we learned that unless this patient used the insurance selected pharmacy, his copay would be elevated ongoing. He stated he could not afford that financially every month. The preferred option, by the insurance provider, was a mail order pharmacy. This creates all kinds of problems for the patient to secure his medication without interruption in therapy. I would be remiss if I did not mention his prescription coverage is handled by CIGNA and the PBM is Express Scripts which is affiliated with/owned by CIGNA. In the retail area we see this all the time, every day, and every week. One size does not fit all. Some patients have trouble with technology, some have financial hurdles, some have transportation problems, and some patients just prefer to work with a pharmacy provider they know and trust. The lack of choice is especially troublesome in rural areas, which is where many independent, community pharmacies are located. While the statistic is promoted that a pharmacist is the most accessible and knowledgeable healthcare provider available, if the pharmacy has closed this is no longer true. In our county, Fauquier, our pharmacy, located in the southern end of the county, is the only pharmacy other than 1 Walgreens outside of Warrenton. That pharmacy does not take some prescription plans (mostly MEDICAID). That means those in the northern end of the county have at least a 15-30 minute trip (one way) to get to a pharmacy. If the closest pharmacy is not in network or the preferred pharmacy, the patient is forced to travel, use mail order, or be negatively impacted financially by using a pharmacy which is a match for their needs. I strongly support a patient's choice to select their pharmacy, provided the contract reimbursements do not negatively affect the pharmacy. In closing, I support HB2107 and respectfully ask this body to support it by moving it along in the legislative process. Al Roberts, Pharmacist/Owner Remington Drug Company Remington, Virginia 22734 540-439-3247

Last Name: choudhary Organization: Virginia Cancer Institute Locality: Glen Allen

I am a practicing Oncologist with Virginia Cancer Institute. I have significant concerns regarding the practice of white bagging. While white bagging has been in place for some time, the number of health plans requiring white bagging and the scope of the drugs included in the policies is increasing. Therefore, the challenges experienced by providers, such as negative financial pressures, increased administrative burden, and adverse impacts on the quality of care they can provide for their patients may be placing their viability at risk. Moreover, payers themselves may not be fully aware of how some operational issues with mandated specialty pharmacy drug acquisition may be eroding any savings from lower drug reimbursement because of errors, delays, and waste. Vizient Inc released a survey analysis which showed the following key findings. -92% of respondents experienced problems with the medication received through white/brown bagging including issues such as wrong drug, damaged product, dose not arriving in time for administration, and dose no longer appropriate due to patient's therapy changes. -95% of respondents experienced operational and safety issues associated with white/brown bagging. The issues encountered included: separate inventory management system, delivery location/security disruptions, lack of space to hold medication (e.g., refrigeration), etc. White bagging is going to put put additional financial impact on delivering timely and effective care to our patients. The insurance requirement dictating white bagging is very unethical and needs to be addressed to provide cost effective care to our oncology patients.

Last Name: McFarlane Locality: Richmond (City)

I am a clinical oncologist practicing in the Richmond area writing to express support for this bill. Allowing insurance companies to create weaknesses in the supply chain of vital and, if used incorrectly, dangerous medication would create a variety of problems. Our patients needed tailored dosing of the medicines we provide in clinic, and they need them reliably on certain dates. Circumventing systems in place to ensure the correct medication is available in the correct amount at the correct time would clearly open patients to harm. It certainly requires a lot of time and attention for our practice to manage the logistics of this task; managing separate supplies for individual patients would magnify the burden and exponentially multiply the points of failure along the the journey of the medication to our clinics.

Last Name: Gonzalez Organization: VCI Locality: Midlothian

I would like to share the concerns regarding white bagging expressed by my colleagues. It will shift the cost of care towards patients as well as compromise continuity of care.

Last Name: Voelzke Organization: Virginia Cancer Institute Locality: Henrico

I have a lot of concerns regarding "white bagging." It has the real risk of increasing out of pocket costs to patients. In addition, there is a substantial risk for delays in patient treatment due to increased coordination of care through an intermediary. Most importantly, there is a clear patient safety concern. Proper handling of chemotherapy is vital to the safety of administering medications to patients. White bagging adds points of potential failure in the supply chain and puts patient safety at risk. Lastly, by adding a third party, it creates clinical treatment challenges. Changes in patient symptoms and lab results often necessitate a need to adjust a patient’s treatment protocol on the day of treatment. This would not be possible with white bagging.

Last Name: Khatcheressian Organization: Virginia Cancer Institute Locality: Richmond

As a practicing oncologist for the last 20 years, I have significant significant concerns regarding "what bagging" as it pertains to the care of my patients. My concerns as follows: 1. White bagging shifts the insurance coverage from the medical benefit to the pharmacy benefit which can result in increased out of pocket costs to patients 2. It creates risks for delays in patient treatment due to increased coordination of care through an intermediary, as well as order fulfillment delays and delivery delays 3. Patient safety and drug integrity concerns – proper handling of chemotherapy is vital to the safety of administering medications to patients. White bagging adds points of potential failure in the supply chain and puts patient safety at risk. Limits ability to continue treatment on time if a dose comes damaged in shipping. 4. Supply management challenges – managing stock that is unique to each individual patient creates both space challenges and increased administrative burden to coordinate and control each patient medication dose. 5. Difficulties managing clinical treatment changes – Patient symptoms and lab results often indicate a need to adjust a patient’s treatment protocol on the day of treatment. When a medication is already filled and is restricted to use for one patient it becomes challenging to make changes on the day of treatment leading to delays in care and unnecessary medication waste.

Last Name: Grizzard Organization: Virginia Cancer Institute Locality: Richmond, VA

Delegates, I am a pharmacist with Virginia Caner Institute and I want to thank you for considering this bill which has enormous impact on our patients. The complications and treatment delays which occur with insurance-driven white bagging are numerous. To summarize briefly some the main problems, white bagging requirements often shifts the insurance coverage from the medical benefit to the pharmacy benefit which can result in increased out of pocket costs to patients at a time they are not prepared to pay the full lump sum. More importantly, this requirement causes delays in patient treatment due to the cumbersome coordination of care through an intermediary, as well as order fulfillment and shipping delays. These medications are often urgent and these delays cause unnecessary hospitalizations, treatment delays for patients undergoing life-saving chemotherapy, and immense emotional stress on our patients. As a pharmacist, I also must focus on patient safety concerns – proper handling of chemotherapy and ancillary medications is vital to the safety of administering medications to patients. White bagging adds points of potential failure in the supply chain and puts patient safety and drug integrity at risk. Drug that arrives at improper temperature or otherwise damaged limits our ability to continue treatment on time. Again, this delays treatment and adds to patient stress. White-bagging also creates enormous supply management challenges – managing stock that is unique to each individual patient creates both space challenges and increased administrative burden for our healthcare team. This time should be spent on providing high-quality care to our deserving patients, not coordinating paperwork and managing stock . Furthermore, these patients often require changes in treatment . As clinicians, white-bagging requirements make it impossible to adjust a patient’s treatment protocol on the day of treatment. Again, this causes patients to miss treatments or suffer another delay in care. As you can imagine, this also contributes to unnecessary medication waste of very expensive medications, thus contributing to higher overall healthcare costs for us all. I hope this highlights some of the concerns with what I see as the extraordinarily unethical practice of white-bagging, intended ONLY to benefit the insurance company and the "specialty pharmacy" that the insurance company or PBM, more often than not, has ownership in as well. To break it down to pros and cons of this practice, there is not a single "pro" that is realized by any patient, provider, or the healthcare system as a whole. The only "pros" are for the insurance companies and/or the PBM that is benefitting financially while driving up costs for our patients and impeding care. To repeat, in my opinion, the insurance requirements dictating white-bagging are highly unethical and I greatly appreciate you addressing this bill to help our patients as they navigate through a difficult time, and to help us, as practitioners, to provide the most appropriate and cost-effective care for our community.

Last Name: Coffey Organization: Riverside Health, VSHP, VPhA Locality: Yorktown

I would like to express my support of HB 2107 Health insurance; pharmacies; freedom of choice; delivery of prescription drugs; penalties. Non-medically integrated Specialty Pharmacies do not provide the same pharmaceutical oversight and safeguards that a medically integrated pharmacy is able to provide. Mail order pharmacies lack up-to-date clinical information such as labs, clinical notes and complete medication lists to thoroughly evaluate appropriateness of therapy. Since the health system owned pharmacy has full access to the patient’s medical record, they can accurately screen for drug interactions and contraindications whereas other pharmacies may not have the entire medication profile. These pharmacists also have close coordination between the providers and patients. Drug pedigree, storage, and handling of product from manufacturers to the patients cannot be insured when using drug from clinic supply or non-integrated pharmacies, especially with medications that require special handling such as refrigeration. Often the practice or the inpatient pharmacy are not contacted to inform of the expected drug delivery and high-cost drugs upwards to $20 to $30K are left to spoil on the loading docks. Or due to the lack of coordination of drug delivery, the patient arrives for their infusion or injection and the medication shipment was delayed, requiring rescheduling of doctor visits and deferring patient treatment which may be detrimental to patient care and outcomes. Once the practice receives the medications, they assume responsibility and the liability for the drug integrity. One must also consider the drug waste if the patient arrives to their visit and the therapy is changed. Once the drug leaves the dispensing pharmacy, it can not be returned. If it is a medically integrated pharmacy, there is coordinated delivery to prevent treatment delays, storage issues and drug waste. I would like to close with a real-life patient experience. Our patient was being treated with Neulasta (WBC growth factor used to prevent neutropenic fever caused by chemotherapy) which shifted from her medical benefit to her pharmacy benefit. This required the medication to be white bagged or self-administered or home health administration. Due to this shift, there was a delay and the patient received one dose of chemotherapy without the Neulasta. She developed chemo-induced neutropenia which required 14 days of antibiotics and the second cycle of chemo was canceled because the Neulasta was still unavailable. I ask you, should this not have been the patient’s choice? I can not help but to think in this situation with better medication adherence by removing barriers, this patient would have had better outcomes while also reducing medical spend to her insurance.

Last Name: McCoy Organization: Virginia Cancer Institute. Locality: Moseley

The dangers of white bagging therapy for chemotherapy are detrimental to patients with regard to same day dose adjustments, procurement and safety. This practice places business over patient care and safety. As a Doctor of oncology and hematology. This process makes little sense in a first world nation.

Last Name: Hagan Organization: Virginia Cancer Institute Locality: Mechacisville

Dear Members of the Labor and Commerce Committee, My name is Kelly Hagan MD FACP and I have been a practicing hematologist oncologist with Virginia Cancer Institute in Mechanicsville for the past 32 years. During this period of time, an incredible number of advances have been made in the treatment of cancers and blood disorders but most unfortunately, most of these advances have come at significant cost. In an ill advised and often dangerous attempt to control costs, insurers have introduced "white bagging" in which insurance companies require that medications be supplied by their chosen third party vendor. This practice can create havoc due to the necessity for increased coordination of care with the third party vendor, increases the likelihood of delay due to the required use of this vendor to fill some, if not all, of the chemotherapy order (as opposed to using stock the MD's office already has) or delays in a specific patient's drugs being delivered (witness the issues created by recent inclement weather, including hurricanes and winter storms). Additionally, patients often come to the office to get their chemotherapy but due to disease progression, the chemotherapy regimen may need to be changed that day or supportive care drugs may need to be added or if the patient has lost or gained weight, the drug doses may need to be changed to accommodate this new reality. We usually check laboratories the day of therapy to make sure the blood counts are adequate for chemotherapy and that the kidney and liver function tests are in a safe range for administration of those agents. If these labs are not in the safe range, changes in the drug regimen are made that same day - this will not be possible with white bagging, again introducing unnecessary delay and anxiety. The administrative burden and space requirements of trying to keep specific patients' drugs separate and safely stored creates an undue burden on the health care provider and increases costs for that provider. If a drug for a specific patient arrives damaged, there are additional challenges, again leading to delay in treatment and patient anxiety. If the drugs do not arrive on time or are damaged during shipment, the patient will need to reschedule their infusions, creating anxiety as well an incredible burden on the infusion center which has a limited number of infusion chairs which are generally tightly scheduled. The caregivers that need to drive the patients to the infusion centers then have to change their schedules as well which creates hardships at their workplace. The relationships that my practice has developed with our vendors is one based on years of familiarity and trust and the same can not be said for the third party vendors that an insurance company may have selected for cost considerations rather than for a known history of quality and integrity. A rather cynical view of white bagging is to note that the change in the insurance coverage from the medical benefit to the pharmacy benefit results in increased out of pocket costs of patients. With a disease as terrible as cancer, the goal of those who take care of them is to deliver the safest, highest quality of care with minimal disruption to the patient's physical and psychological well being, while attending to the unique circumstances and needs of the patient and their caregivers. Allow us to do the jobs we have been trained to do and have become adept at doing. Please support HB 2107.

Last Name: Shah Organization: Virginia Locality: Richmond

Honorable Members, I respectfully submit this testimony in support of HB2107 in large part because of my opposition to the practice of mandatory white bagging. As a practicing medical oncologist , I see the repercussions of this policy to my patients every day in practice. I urge you to consider the profoundly negative consequences this policy can have on patients, healthcare providers, and the integrity of our healthcare system. First and foremost, mandatory white bagging forces patients to rely on medications that are delivered through third-party vendors rather than their trusted healthcare provider, thus stripping away the essential patient-provider relationship, introducing unnecessary delays and complications in the delivery of care, at a time when timely access to medications is crucial for those battling chronic or life-threatening conditions. For most patients, there is a trust that exists between provider and patient, the familiarity of the clinical environment, and the ability to respond swiftly when complications arise. Mandatory white bagging undermines this relationship, as the medications are no longer handled directly by the providers who know their patients best. In cancer care, decisions about dosing are often made on the day of administration based on the clinical condition of the patient, making it critically important for healthcare providers to have timely control over the process. It places an overwhelming administrative burden, especially to those in smaller and rural communities, as they struggle with the added complexity of managing these external pharmaceutical channels. It increases operational costs and causes potential delays in treatment, which may cause harm to those who can least afford it. Most critically, the emotional and mental toll this practice on patients already grappling with serious health conditions, like cancer , navigating a labyrinth of external pharmaceutical distributors adds an unnecessary layer of stress and uncertainty to their already challenging healthcare journey. I urge you to protect the health, dignity, and well-being of Virginians by opposing mandatory white bagging. It is imperative that we safeguard patient access to timely and effective care, support healthcare providers in their critical roles, and ensure that the system remains focused on the needs of the people it serves. Thank you for your time and consideration. Sincerely,
Purvi Shah
 Virginia Cancer Institute Richmond, VA Pshah@vacancer.com

Last Name: Skorupa Organization: Cancer Specialists of Tidewater Locality: Va Beach

I am a practicing oncologist in Virginia Beach. White bagging is yet another way insurance companies control patient care without any regard for a patient's care. When insurance companies require that they supply the injected medication, my staff and I do not have control over the medication. For example, I have the pleasure of taking care of a 33yo woman with breast cancer. Her insurance required that they supply a medication Udenyca directly to her. This is a commonly used injectable medication to boost a patient's white blood cells when they are receiving chemotherapy. She received 3 vials of Udenyca which were cloudy. The product information clearly states the medication should NOT be used if cloudy. None of these vials could be used for her. However, we had safe product in the office that we could have used for her. This is one example of how this practice creates treatment delays which impact a patient's health. In addition, this creates a huge amount of anxiety for patients and their families. Please support HB2107 to restrict this practice in Virginia for the health of our Commonwealth.

Last Name: Marchand Organization: virginiacancer.com Locality: Norfolk

I am the Director of Pharmacy and Admixture Services at Virginia Oncology Associates and would appreciate the opportunity to share my opinion and experience in this matter. Treatment of cancer care today is highly personalized and tailored toward each individual patient. Chemotherapies consist of complex drug regimens that are dynamic and frequently adjusted at the point of care based on a patient's ever-changing circumstance, such as disease progression, co-morbidities, and weight variation, as well as the drug's toxicity and side effects. Issues as we see them with white bagging: 1. A patient must wait until the drug is delivered to the oncologist. Day-of-dose adjustments are not possible. Delivery issues, damage, or administrative hurdles can delay care by days or even weeks. Delays may cause disease progression. 2. Creates drug waste. If a patient requires a dose change (increase, decrease or a treatment change), that dose cannot be used for the intended patient and also cannot be used for another patient, resulting in drug waste. 3. Supply Chain Integrity. Patients could be at risk for contaminated or counterfeit products. Our practice utilizes a closed supply distribution system that ensure the integrity of all products given to patients. 4. Increased out-of-pocket costs. When an insurer mandates white bagging, the treatment is typically switched from the patient's medical benefit to his/her pharmacy benefit, which often has higher cost-sharing responsibilities.

Last Name: Neace Organization: VSHP Locality: Afton

Delegates, I respectfully request your support for HB2107, which aims to restore patient choice for individuals seeking treatment for debilitating conditions, including advanced cancer. The practice known as "White-Bagging" occurs when insurance companies require certain high-cost medications to be supplied by their own specialty pharmacies to healthcare providers. This practice circumvents the patient and raises significant safety concerns, such as delays in medication delivery and interruptions to the patient's treatment plan. The healthcare provider faces challenges due to limited control over the medication supply chain, leading to additional strains on staff at infusion centers. These facilities must navigate the complexities of managing white-bagged medications, which require special refrigeration resources often at the provider's expense, as well as increased staffing needs to handle these additional processes. Furthermore, providers are compensated solely for the infusion time, which does not generate sufficient revenue to sustain their operations. When the supply chain breaks down, patients may leave their appointments untreated and must return later, which can place significant burdens on their family and friends. These caregivers often need to adjust their work schedules to accommodate the patient’s treatment. Additionally, as disease progression occurs, many patients find it increasingly difficult to attend appointments due to their weakened states. Many of these patients experience severe nausea and vomiting in anticipation of chemotherapy, heightening their distress when they learn that their medication is unavailable. When patients arrive and are informed that their medication cannot be provided, the emotional impact falls squarely on both the patients and the healthcare staff, who are tasked with managing this disappointment. Addressing these concerns is crucial for ensuring a more efficient and compassionate healthcare experience. Patients may not fully understand the intricate series of events required to ensure that their medications are available onsite for timely and effective treatment. Medications can often experience delays, such as being left on a loading dock without reaching their intended location, compromising their cold chain storage, or being misplaced within facilities during weekends. Delays in shipping can also arise from unforeseen circumstances. Additionally, challenges arise when a patient’s therapy requires modification due to lab results, lack of response to treatment, or necessary dosage adjustments. In these cases, patients frequently do not receive their medication on time, which can lead to significant delays in their care. Furthermore, when a change in therapy is warranted, the medication—although it may be available—must return to the specialty pharmacy through the same shipping channels and adhere to cold chain requirements, usually within a 30-day timeframe for the patient to receive proper credit. This process is often fraught with difficulties stemming from the complexities of managing white bag medications. In conclusion, this situation creates unnecessary challenges for everyone involved. I kindly urge your support for HB2107 to streamline this process, aligning Virginia with several other states that have successfully prohibited this practice. Thank you for your consideration. Michael Neace, PharmD, MBA President-Elect, Virginia Society of Health-System Pharmacists (VSHP) Afton, VA

Last Name: Ingram Organization: Virginia Association of Hematologists Oncologists Locality: Winchester

Comments Document

Dear Members of the Labor and Commerce Committee, My name is Richard Ingram, MD, and I serve as both a practicing oncologist and hematologist at Shenandoah Oncology in Winchester, Virginia, and the President of the Virginia Association of Hematologists and Oncologists (VAHO). I appreciate the opportunity to testify in strong support of HB 2107. This critical legislation seeks to extend existing statutory protections that uphold patient freedom of choice in pharmacy selection, specifically concerning physician-administered medications. The passage of this bill is of paramount importance to me, my colleagues, and the cancer patients we are dedicated to serving. Oncologists like myself design personalized treatment plans tailored to the unique needs of our patients. These plans involve multiple medications that are clinically interconnected and require precise scheduling. The dosages often depend on the patient's real-time clinical presentation, which involves numerous variables unique to each patient and clinical encounter. Historically, practices like mine have maintained in-office inventories of oncologic medications, enabling us to respond swiftly to same-day clinical parameters and deliver the right drug and dose to each patient in real time. However, we at Virginia Association of Hematologists Oncologists have observed a concerning trend: certain payers are increasingly imposing MANDATORY white bagging policies. These policies require that physician-administered drugs be sent as individual doses from designated pharmacies directly to infusion clinics, creating significant challenges. White bagging introduces issues such as drug waste, liability, logistical complexities, and cost shifting to patients' pharmacy benefits. Most concerning is the potential for delays in care delivery. If a drug arrives mis-dosed, damaged, or late, it disrupts the patient's treatment schedule, compounding risks with each delay and adversely affecting outcomes. Cancer patients deserve empowerment over their treatment delivery mechanisms. White bagging should be A CHOICE, NOT A MANDATE. Patients should have the option to collaborate with their oncology team to determine if this approach suits them or refuse it if it jeopardizes their outcomes. Forcing patients to navigate additional variables and barriers diminishes their chances of recovery and remission. In support of my testimony, I have attached an infographic that offers a comprehensive overview of white bagging. It includes patient testimonials detailing the negative impacts on their clinical care plans, data from an Avalere study illustrating the impact on patient care, and the administrative cost burdens associated with white bagging. Thank you for your time and consideration in supporting HB 2107. Sincerely, Richard M Ingram, MD President, Virginia Association of Hematologists and Oncologists

Last Name: McDaniel Locality: Roanoke County

Delegates, HB2107 protects patient safety and preserves access to timely, coordinated care by prohibiting mandatory white bagging. This bill ensures patients have the freedom to choose their pharmacy, upholds medication integrity, and maintains the safety of established healthcare workflows while reducing delays and administrative burdens caused by payer-mandated practices.  White bagging creates risk for patients  White bagging results in delays in care  White bagging increases anxiety and financial burden on patients  White bagging creates challenges for health systems  White bagging is anti-choice Support HB2107 Brad McDaniel, PharmD, MBA, BCCCP Roanoke, VA

HB2133 - Health insurance; coverage for breast examinations for high-risk individuals.
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