0990-RW Study Appendix C - Public Comments_06-14-13

APPENDIX C
PUBLIC COMMENTS FROM EXTERNAL CONSULTANTS

April 30, 2012
Ms. Sherette Funn-Coleman
OS Paperwork Clearance Officer
U.S. Department of Health and Human Services
200 Independence Ave. SW
Washington DC 20201
Re: Ryan White HIV/AIDS Program Modeling Project--OMB No. 0990-New-Office of the Assistant
Secretary for Planning and Evaluation
Dear Ms. Funn-Coleman:
The AIDS Institute, a national organization that promotes action for social change through public
policy research, advocacy, and community education, is pleased to comment in support of the
proposed modeling project by the Office of the Assistant Secretary for Planning and Evaluation
(ASPE) on the Ryan White HIV/AIDS Program. We believe the questions ASPE has developed in its
questionnaire are adequate and essential in determining how the existing Ryan White HIV/AIDS
Program will evolve as the Affordable Care Act (ACA) is implemented.
Implementation of ACA and coordinating the coverage that it provides to the over half of a million
people with HIV/AIDS who receive benefits under the Ryan White HIV/AIDS Program is one of The
AIDS Institute’s highest priorities. While we are looking forward to expanding health care coverage to
more people through ACA, many of whom have HIV/AIDS, we are cognizant that there is a current
system of care and treatment for low income people with HIV in the Ryan White Program. It will be
critical to determine how the current Ryan White Program can best prepare for ACA implementation
and what needs will still exist under the Ryan White Program when ACA is implemented.
We believe the questions developed by ASPE and the information that will be collected will be
extremely useful in determining how to best meet the care and treatment needs of people living with
HIV/AIDS in the United States. Providing care and treatment to people with HIV/AIDS is a goal of
great public health significance and is included in the President’s National HIV/AIDS Strategy.
For your consideration, we offer the following specific comments on the proposed questions for Part A
and B grantees:

“Promoting action for social change through public policy research, advocacy, and education”
rd

2000 S Street, NW, 3 Floor, Washington, DC 20009 / PH 202 835 8373 FX 202 835 8368
17 Davis Blvd. Suite 403, Tampa, FL 33606 / PH 813 258 5929 / FX 813 258 5939
www.theaidsinstitute.org

Question C. 5: Respondents should be made aware that there is a waiver process in meeting this
requirement.
Question D. 1: The question should also include the opportunity to identify funding from other Parts
of the Ryan White Program in their jurisdiction.
We also believe a question should be included on whether the grantee is prepared for billing and
provides any funding, education, technical assistance on billing of medical services and treatment. The
issue of billing was included in the provider questionnaire but we believe this topic should also be
addressed in the Part A and B grantee questionnaire since it is relevant and extremely critical to their
work in the future.
As you move forward to begin the process of interviewing the grantees and providers, we believe since
the answers are very complicated and will require some advance thinking and research, we are
assuming that they will be sent to respondents far before the actual interview.
The AIDS Institute appreciates the opportunity to submit these comments. Should you have any
questions or comments, please feel free to contact me at 202/462-3042 or
cschmid@theaidsinstitute.org. Thank you very much.
Sincerely,

Carl E. Schmid II
Deputy Executive Director

“Promoting action for social change through public policy research, advocacy, and education”
rd

2000 S Street, NW, 3 Floor, Washington, DC 20009 / PH 202 835 8373 FX 202 835 8368
17 Davis Blvd. Suite 403, Tampa, FL 33606 / PH 813 258 5929 / FX 813 258 5939
www.theaidsinstitute.org

April 26, 2012
Sherette Funn-Coleman
Office of the Assistant Secretary for Planning and Evaluation (ASPE)
200 Independence Avenue S.W.
Washington, D.C. 20201
To Whom it May Concern:
On behalf of the National Alliance of State and Territorial AIDS Directors
(NASTAD), which represents the public health officials that administer state and
territorial HIV/AIDS and adult viral hepatitis prevention and care programs
nationwide, I am writing to provide comments regarding the proposed project:
Ryan White HIV/AIDS Program Modeling Project. AIDS Directors administer
Part B and the AIDS Drug Assistance Programs (ADAPS) of the Ryan White
Program.
In conducting the above-referenced study, it will be important to assure that the
proposed respondents to be included in the study represent:
 The geographic distribution of the HIV/AIDS epidemic in the United
States
 Grantees with varying burden of the epidemic (low, medium and high
incidence jurisdictions)
 Grantees with varying level of experience preparing for the
implementation of health reform
In addition, NASTAD recommends that Ryan White clients, case managers,
clinicians, pharmacists and community stakeholders also be included in the study
as their experiences with the Program will be impacted by the implementation of
health reform.Individuals should be provided anonymity via informed consent to
assure collection of full and accurate information.
In order to enhance the quality, utility, and clarity of the information to be
collected, NASTAD recommends that the study be more reflective of the overall
Ryan White Program. The current topics to be addressed (HIV service needs and
use; coordination of client insurance enrollment, benefits, and services; factors
that influence variation in HIV care costs and selection of AIDS Drug Assistance
Program cost containment procedures; and methods of ensuring quality care)
should be expanded to assess the impact of health reform on the need for
expanded access to care of all individuals living with HIV, the ability of all Parts
of the Ryan White Program to wrap-around insurance, and the effect that access
to insurance will have on the current structure of Ryan White.
NASTAD believes that the Ryan White Program must continue both as the
Affordable Care Act is implemented and after implementation is complete. With
many more individuals having insurance coverage (through Medicaid expansion
and health exchanges) in 2014, it will be essential for Ryan White programs to
provide care within the exchanges and continue to provide specialty HIV/AIDS

care. In June 2011, 31% of ADAP clients served were enrolled in Medicaid and/or Medicare;
Ryan White will continue to have to provide wrap around services after 2014. In addition to
filling in gaps in existing insurance, the Ryan White Program will provide coverage of clients
not eligible for health reform. Ryan White will also need to continue to provide case
management services and other supportive services, as they are a crucial aspect of keeping
people living with HIV/AIDS in care and helping clients access services and treatment.
Thank you for the opportunity to provide comments on the proposed project: Ryan White
HIV/AIDS Program Modeling Project. We appreciate your attention and consideration of these
comments. Please do not hesitate to contact me at (202) 434-8090 or by email at
jscofield@NASTAD.org if you have questions related to these comments.
Sincerely,

Julie M. Scofield
Executive Director