Public Comments for 01/28/2025 Labor and Commerce - Subcommittee #1
HB2100 - Medicare supplement policies; annual open enrollment period, individual Medicare policies, etc.
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.
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
Support bill
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.
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.
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.
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
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
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.
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!
HB2208 - Health insurance; coverage for at-home blood pressure monitors, report.
HB2258 - Bureau of Insurance of SCC; step therapy protocols for health benefit plans, report.
Please see attached written comments in support of HB2258 and HB2773 from the Infusion Access Foundation.
Please see attached document outlining the National Infusion Center Association's support for HB 2258 and HB 2773.
Dear Chair Ward and Members of the House Labor and Commerce Committee, I’m writing in support of HB 2258 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. When medically inappropriate, step therapy delays access to needed care and can lead to severe or irreversible health outcomes for patients. Most Americans receive insurance through their employer, and it is important to establish a meaningful step therapy exception process for this segment to ensure timely access to medically necessary care. Payer-mandated step therapy protocols are included in employer plans and research has shown that they often conflict with clinical guidelines, increase overall healthcare spending, and delay access to needed care. HB 2258 requires the Virginia Bureau of Insurance to collect and study data on oncology step therapy protocols and the time frame for final decisions regarding step therapy. Since the study commissioned by HB 2258 would provide insight into the impact step therapy has on cancer outcomes and what policy solutions would improve outcomes for patients, ZERO Prostate Cancer recommends passage of HB 2258. Please follow up with georgia@zerocancer.org with any questions.
HB2320 - Workers' compensation; presumption of compensability for lymphoma or myeloma.
HB2329 - Health insurance; prescription drug formularies.
HB2371 - Health insurance; coverage for contraceptive drugs and devices.
The League of Women Voters of Virginia supports HB2371. We believe that contraceptives should be accessible to all. Eliminating burdensome co-pays, cost-sharing, reimbursement requirements, and coverage delays would help decrease barriers to utilization of contraception thus increasing reproductive health equity in Virginia. Accessible contraception is critical for a range of reasons including and beyond preventing pregnancy. This essential care includes treating a range of healthcare needs such as hormonal regulation, endometriosis, uterine fibroids, and ovarian cysts, just to name a few. We urge you to support HB2371.
HB2392 - Health insurance; pharmacy benefits managers, definition of "covered entity."
HB2481 - Workers' compensation; injuries caused by repetitive and sustained physical stressors.
HB2525 - Health insurance; electronic prior authorization, report.
HB2611 - Health insurance; coverage for cancer follow-up testing, report.
Dear Chair Ward and Members of the House Labor and Commerce Committee, I’m writing in support of HB 2611 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. Decades of research has consistently shown that eliminating cost-sharing for cancer screening increases screening utilization, but the State of Virginia has lacked the data to study the impact of eliminating cost-sharing on screening utilization, as was the case with the Virginia Bureau of Insurance’s analysis of HB 477 (2022). HB 2611 would give valuable insight into insurer cost-sharing practices for potentially life-saving services, including for imaging services, which are increasingly being used to screen for prostate cancer and to reduce overdiagnosis and unnecessary biopsies. ZERO Prostate Cancer supports HB 2611 and efforts to study the impact of eliminating cost-sharing on service utilization and to improve access to medically necessary screening and diagnostic services to detect prostate cancer. Please follow up with georgia@zerocancer.org with any questions.
HB2671 - Authorized septic system inspectors; definitions, minimum requirements, penalty.
The purpose for this attachment is in support of House Bill no.2671, section 59.1-310.9
I am writing to express my support of HB2671. This bill updates who can perform septic inspections and provides minimum inspection requirements which in turn will standardize these inspections across the state. In my 20 years in the industry one of the most inconsistent aspects of the industry has been the inspection, resulting in many upset homeowners with septic problems that could have been addressed before their transaction. HB2671 will help in eliminating many of these issues and provide more successful real estate transactions for all parties involved. I strongly urge the legislature to pass HB2671 to provide consistency for real estate transactions though out the state.
As the current president of VOWRA (Virginia Onsite Wastewater Recyling Association) we support this bill with the additions as submitted.
I am writing to express my strong support for HB2671, which aims to remove the outdated designation of an "accredited septic system inspector" from the Code. This term was established before the Department of Professional and Occupational Regulation (DPOR) set up a comprehensive licensing program for septic system designers, inspectors, and installers. The bill also defines the minimum inspection requirements for conventional, alternative, and alternative discharging systems, which will standardize septic system inspections for real estate transactions across Virginia. By bringing consistency and reducing variability between localities and inspectors, HB2671 ensures a more reliable process for all stakeholders involved in real estate transactions. It also provides clear guidelines for the DPOR to evaluate complaints related to septic system inspections, further enhancing transparency and accountability in the industry. I urge the legislature to pass HB2671 to streamline and improve septic system inspections across the state.
HB2738 - Health insurance; coverage for mental health and substance abuse disorders.
Please support this bill to require insurance companies to apply generally accepted standards of care when making medical necessity review determinations for mental health, substance use disorders, addiction, and behavioral health. An insurance company should not be making medical decisions, each individual's medical provider should be making that decision. When an insurance company does not apply generally accepted standards of care when making medical necessity review determinations, patients do not get the medical care that (1) their medical provider recommends for them and (2) that the patient needs for their health.
I am writing to express my strong support for House Bill 2738, which seeks to ensure that health insurance plans in Virginia provide comprehensive coverage for mental health and substance use disorder treatment. As someone deeply invested in the well-being of individuals in our community, I believe this bill is a critical step toward addressing the ongoing mental health crisis and underserved members in our state. HB2738 requires insurance providers to cover mental health and substance use disorder services under the same medical necessity standards used for other health conditions. This ensures that individuals receive timely and appropriate care based on clinically accepted practices, rather than arbitrary or restrictive insurance policies. Additionally, the bill mandates parity between mental health/substance use disorder benefits and medical/surgical benefits, aligning with the federal Mental Health Parity and Addiction Equity Act . As a provider of Applied Behavior Analysis (ABA) services through Blue Ridge Autism Care, I have witnessed firsthand how delays and denials in mental health treatment can have devastating consequences. Many individuals in our area struggle to access necessary care due to insurance barriers, and HB2738 would provide much-needed relief by ensuring fair and standardized coverage. Mental health conditions and substance use disorders are treatable, but only if individuals can access the services they need without unnecessary delays or denials. I urge you to support HB2738 to strengthen Virginia’s mental health system and provide critical protections for those in need. Thank you for your time and consideration. I look forward to your support for this important legislation.
Please pass this. As a provider of individuals with IDD and other mental health diagnosis (bi-polar, schizophrenia, etc.), treatment works and should not be hassle to get coverage for. Thank you, Dr. Robin Moyher
Authorization denials for ABA therapy contradict the generally accepted standards of care.
There are so many families who find barriers in seeking the care and education that their children with disabilities require. We pay high insurance bills but when it comes time to apply this money to a specific disability the insurance companies don't want to pay for services. This hurts the families and the providers of these services. The providers have to make a reasonable living for the work they do, but many cannot afford to provide services at the rate the insurance companies want to pay. Please hold the insurance companies accountable so that our children of Virginia can receive the services that they need. Thank you
Hello! I am respectfully urging members of the house to pass this bill to provide coverage for desperately needed mental health services for the patients and families that I serve. Children and adults who are able to access our services can have life changing results from evidence-based therapies. I am only asking that you consider this as if your own family member needed life-saving treatment. Would this not be the same coverage you would want for them? If so, then please pass this bill!
Please see attached written testimonial on behalf of myself and my company
Dear Representatives, Please support HB2738. Many Americans are in need of care for behavioral and mental health, substance abuse, and addiction issues. Please support the removal of additional barriers for these very real medical concerns which require generally accepted standards of care. As a practitioner of Applied Behavior Analysis, I can speak to the positive treatment outcomes which benefit individuals, families, and communities when individuals in need receive much-needed quality services like ours. Thank you , Delegates Sickles and Torian for championing this bill.
Members of Labor and Commerce sub-committee, I'm writing on behalf of Capital ABA, an-home behavioral healthcare agency that has served Virginia families for nearly 15 years, asking you to vote in support of HB2738. It is all too common for commercial health insurances to impose extraneous hurdles to utilization management decisions, at minimum delaying service provision, and at worst denying medically necessary services all together. Requiring insurance companies use generally accepted standards of care when making healthcare utilization decisions will improve patient access to medically necessary services. Thank you,
I am writing in support of this bill as a person, parent, and provider of services for individuals impacted by mental health issues. This bill will hold insurance companies accountable for contributing to the solution by providing proper treatment to those who need services.
Please support this bill to help families and children who desperately need services and are often denied services based on non-relevant criteria set by insurance companies. These families need these critical services.
My name is Tyler Williamson and I am the CEO of FACT (Families of Autism Coming Together). We are a nonprofit serving 400+ kids and adults with autism in Hampton Roads. I am writing in strong support of HB2738 to require insurance companies to apply generally accepted standards of care when making medical necessity review determinations for mental health, substance use disorders, addiction and behavioral health. In addition to being CEO of FACT, I am also the older brother of an amazing autistic adult named Brian Williamson who lives in Chesapeake but does have some significant behavioral issues. I strongly encourage to you support this bill and allow medical and mental health professionals, and not the self-interested insurance companies, to be the ones to determine what is medically necessary for those dealing with various mental health issues. Many autistic individuals have significant behavioral health and mentals health needs and issues. These needs are going unmet and programs to support them are being closed because the insurance companies are denying their claims. The insurance companies, who have a clear monetary bias to rule against providing help, should not be allowed to unilaterally determine when these services are needed. That should be left to medical professionals and reflected in the generally accepted standards of care. Please support HB2738 and help families and individuals get the important services they need, when they need them, to help prevent tragedies and these issues from becoming worse. Our government needs to start to being proactive, not reactive, when it comes to mental health issues and this will end up saving the system money in the long run. Thanks Tyler
I have attached comments in support of HB 2738 from the Council of Autism Service Providers.
Delegates, On behalf of the Behavioral Health Providers Coalition, which represents seven of the largest behavioral health professional associations across the state, I urge you to pass HB2738. This legislation is critical to ensuring that individuals with mental health and substance use disorders receive the care they need, based on evidence-based standards rather than insurer-defined criteria. In September 2024, our organization conducted a statewide survey, gathering over 300 responses from behavioral health providers in just three weeks. The results highlighted a troubling trend: insurance denials are among the leading causes of harm to patients. For individuals struggling with mental health and substance use disorders, such denials significantly increase the risk of suicide and other adverse outcomes. Historically, mental health and substance use disorders have been stigmatized, leading to systemic inequities in treatment access and coverage. HB2738 aims to address this disparity by strengthening Virginia’s parity law and providing critical protections for individuals with these conditions. Current law allows insurers to use proprietary, profit-driven criteria to determine whether treatment is covered. This practice undermines the goal of parity and jeopardizes patient outcomes. Data from the Virginia Bureau of Insurance’s 2024 report further underscores the disparities. In 2023, 5 categories of denials were measured. Mental health emergency care claims were denied 4.9% more frequently than medical/surgical claims. Substance use disorder claims faced an even starker disparity, with denial rates 13.4% higher than those for medical/surgical benefits. For office visits, denials for MH were 1% higher and SUD claims 17.6% higher. Across the 5 measured categories, substance use denials exceeded medical/surgical denials in every category. When these denials were appealed through external review, 55.6% of mental health and substance use disorder claims were overturned, compared to 48.8% for medical/surgical claims. Additionally 52.6% of the complaints received related to substance use disorder benefits were related to utilization management review. 22.6% of the complaints for mental health were related to access to care compared to 10.1% for medical/surgical. These figures make it clear that insurers are not applying fair or consistent standards when determining coverage. HB2738 offers a straightforward solution: it requires insurers to use generally accepted standards of care when determining coverage for mental health and substance use disorders. These standards, developed by professionals in the field, ensure that decisions are based on evidence and clinical best practices rather than financial incentives. This bill does not impose new or unreasonable burdens on insurers. Instead, it holds them accountable to the standards they should already be meeting from both a parity and ethical standpoint. Passing HB2738 will save lives, improve health outcomes, and help dismantle the longstanding inequities in mental health and substance use treatment. I urge you to support this bill and take a vital step toward ensuring that all Virginians can access the care they need and deserve. Sincerely, Rebecca Kaderli Chair Virginia Behavioral Health Providers Coalition BOI report: https://rga.lis.virginia.gov/Published/2024/RD712/PDF
Please support HB2738 so that Virginians in need of mental health care can receive it. Right now, insurance companies deny care that has been recommended to Virginians by their healthcare providers by using medical necessity criteria that are more strict than generally accepted standards of care. These more strict guidelines only serve to create barriers to needed care for Virginians while increasing profits for the insurance companies. Decisions about what level of care is needed for a person should be made by the treating provider and the patient following accepted standards of care - NOT by reviewers who are unfamiliar with the case, uninvolved in the treatment process, and using guidelines that do not align with accepted standards of care.
HB2769 - Life or health insurances; unfair discrimination, pre-exposure prophylaxis for prevention of HIV.
HB2773 - Health insurance; cost-sharing, pharmacy benefits managers, compensation and duties, civil penalty.
I greatly appreciate your bring forth this legislation which will aid in the improvement of access to pharmacy benefits for many Virginians. As you know PBMs have placed themselves in a position of profiting hugely from the administration and delivery of drugs to our patients and citizens in VA. Instead of acting in a fiduciary capacity for the best interest of patients in VA, they have only looked to improve their bottom line. The attached recent articles give us further evidence that this needs to stop immediately. With your legislation, we can make this happen. As a nephrologist, my patients tend to be on 12-15 medications at a time. The copays, coinsurance and deductibles applied to these medications have become an overwhelming impediment to improve their care and condition. As you probably are aware, about 50% of prescriptions over $100.00 are left unfilled at the pharmacy counter each year. I wholeheartedly support applying any rebates or incentives garnered by the PBMs and insurers to be given back to the patients who are on these vital medications, making them more affordable. Mr. Doug Gray from the VA Association of Health Plans indicated that these rebates are given back to patients in the form of lower premiums. The attached articles offer evidence that this is surely not the case. The three larges PBMs have become extremely wealthy doing just the opposite. Thank you for your interest.
Please see attached written comments in support of HB2258 and HB2773 from the Infusion Access Foundation.
Please see attached document outlining the National Infusion Center Association's support for HB 2258 and HB 2773.
HB1942 - Financial institutions; regulation of money transmitters, penalty, effective date.
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.