LETTER TO GOVERNOR CUOMO - SAVE NEW

YORK’S COMMUNITY HEALTHCARE SAFETY NET

DEAR GOVERNOR CUOMO,

We are deeply concerned about the effect the Medicaid pharmacy carve-out will have on New York’s most vulnerable Medicaid
recipients and the health care facilities and organizations that serve them. An explicit charge of the Medicaid Redesign Team
was to “strengthen the sustainability of safety net providers serving vulnerable populations,” but unanticipated consequences
of the carve-out will have an opposite, destabilizing effect. New York’s safety net providers, including community health centers,
Ryan White providers, hospitals, HIV Special Needs Plans (SNPs), and other community-based organizations already operate
on thin to negative margins, and this year have been stretched beyond their limits due to COVID-19.

We strongly support the NYS Senate and Assembly positions opposing implementation of the carve-out. We urge you to
reconsider the implementation of this policy and work with us to repeal the carve-out and collaborate with health care providers
and legislators to find alternative reforms that will provide real savings and greater transparency in management of the
pharmacy benefit without harming the state’s community health program safety net and the people who rely on our services.

The 340B program was established by the federal government in 1992 to give only eligible safety net entities the ability to
purchase drugs at a deep discount, allowing them to stretch scarce resources so that they can provide more comprehensive
care and services and serve more people who would otherwise fall through the cracks. Hospitals, clinics, and community-based
organizations use those savings to assist vulnerable patients in many ways including supplying prescription drugs at reduced
or no cost; providing medical services; and providing wrap-around care such as transportation, housing, and nutrition services,
all leading to higher rates of patients who remain in treatment. SNPs provide critical prescription drug management to people
living with HIV/AIDS (PLWHA) to ensure adherence and completion of therapy. These savings are provided directly by drug
manufacturers as a condition of their participation in the Medicaid program and, as such, are not provided through any state or
federal taxpayer dollars.

For some 340B hospitals, clinics, and community-based organizations as much as 70% of their patient population is covered
by a Medicaid managed care insurance plan, with Medicare and commercial insurance comprising the rest. Because the
carve-out would move these patients’ drug benefit to FFS, the implications for federally qualified health centers (FQHCs), Ryan
White providers, STD clinics, and hospitals that rely on 340B savings will be dire. Furthermore, this proposed cut comes at
a time when covered entities are already facing significant reductions in reimbursement from other payers, and several drug
manufacturers have taken unilateral action to curtail 340B discounts. Any further loss of 340B resources will result in serious
financial cuts that threaten the safety net and access to care for New York’s most vulnerable patients.

The state’s move to divert these resources away from the safety net is ultimately harmful to the state itself, as the loss of 340B
savings will result in service reductions and clinic and hospital closures, leaving vulnerable patients without access to the care
they need. SNP members who lose real-time access to personalized pharmacy benefit teams trained to understand their unique
needs, will have their care compromised. Cancer patients receiving treatment at rural hospital oncology clinics may have to
drive farther for their care. The closure of transitional housing programs to support recently discharged high risk patients could
lead to otherwise avoidable readmissions. The state’s actions and the loss of necessary services such as these will increase
unnecessary utilization of more inherently expensive and already overburdened providers such as ERs and hospitals, and result
in more medical complications and worse health outcomes, all of which will increase the price of taxpayer funded care.

Safety net hospitals, community health centers, and Ryan White providers that are covered entities use savings from the
340B drug discount to be able to provide high quality care and treatment regardless of a patient’s ability to pay or insurance
status. An estimated 15% of the 2.3 million patients served by New York’s community health centers are uninsured and 29% of
patients have another primary language and speak limited English. The 340B program allows neighborhood community health
clinics and other community health programs to provide quality, low-cost or free health services to all New Yorkers, including
new immigrants. Neighborhood community health clinics supported by 340B are deeply embedded in the specific immigrant
communities that they serve, with appropriate language services and cultural competency. The New York Immigration Coalition
and front-line providers that serve new immigrants have vocally opposed the carve-out.

Faith leaders and civil rights leaders have also written urging you to reverse the carve-out. The proposed change will add
additional healthcare, fiscal, and social burdens to communities of color, which have historically suffered from healthcare
disparities and are now disproportionately impacted by COVID-19. Neighborhood community health centers and other
covered entities are vital part of the national COVID-19 vaccination effort, as has recently been stated by President Biden’s
administration, so undermining these community health providers at this time will harm New York’s COVID-19 response and go
against the Biden administration’s and your commitment to addressing racial health disparities.

Labor leaders have also spoken out against the Medicaid pharmacy carve-out, which will lead to the closure of 32 community
health clinics, and the loss of over 700 vital healthcare jobs that provide life-saving services in the most underserved
neighborhoods.

Community health programs supported by 340B are at the forefront of providing health services to New Yorkers experiencing
homelessness. The carve-out will have a devastating and destabilizing impact on health care providers that serve New Yorkers
who are homeless, and disruptions in care, treatment and services to this population will lead to lives lost and a higher burden
of expensive emergency room care.

Harm reduction, overdose prevention, and drug treatment service providers also rely on 340B supported services to provide
quality care to patients and community members. There has been a tragic increase of overdose deaths in New York over the
past year during the COVID-19 pandemic and the state should not be destabilizing safety net providers and instead should be
surging resources to front-line providers at the forefront of addressing the State’s overdose crisis.

Further, safety net providers, health plans, and community organizations serving people living with HIV/AIDS (PLWHA),
hepatitis B and C, have built a successful statewide system in New York that has saved countless lives and made tremendous
progress toward ending the HIV/AIDS and the hepatitis B and C epidemics. Carving out the pharmacy benefit from Medicaid
managed care will lead to decreased access to curative treatments for hepatitis C and a decrease in the HIV viral suppression
rate across our state, thus threatening progress toward your goals of ending the HIV/AIDS epidemic (ETE) and eliminating
hepatitis C.

This new policy will provide little to no benefit to the state and will devastate patients and the safety net providers they rely on
for care. We urge you to reverse the “carve-out” as soon as possible.

SIGNED,
1199SEIU ACT UP New York African Services County (ACQC)
Committee
Acacia Network Advantage Care AIDS Healthcare
After Hours Project Foundation
ACR Health Advantage Care
Health Center AIDS Center of Queens AIDS United
Albany Damien Center Center for HIV Law Drug Policy Alliance Health Care Choices
and Policy NY, Inc.
Alliance for Positive East Harlem Council for
Change Chinese-American Human Services Hepatitis C Mentor and
Planning Council (CPC) Support Group (HCMSG)
American Academy of East Hill Family Medical
HIV Medicine, New York/ Coalition for Hepatitis C Treatment
New Jersey Chapter Homeless Youth Educational Alliance/ Network
Center for Recovery and
Amida Care Coalition for the Homeless Wellness Heritage Health and
Housing, Inc.
Apicha Community Coalition of Medication- Elmcor Youth & Adult
Health Center Assisted Treatment Activities, Inc. His Branches, Inc.
Providers and Advocates
Bailey House (COMPA) Emergency Shelter Hispanic Federation
Network
Beacon Christian Coalition on Positive Hispanic Health Network
Community Health Center Health Empowerment Empire Liver Foundation
(COPE) Hometown Health Centers
Bedford Stuyvesant Family EngageWell IPA
Health Center Commission on the Housing Works
Public’s Health System Equality New York
Betances Health Center Hudson Headwaters
Community Health Action Evergreen Health Services Health Network
BMS Health and Wellness Staten Island (CHASI)
Centers Ezras Choilim Health Hudson Valley
Community Health Care Center Community Services
BOOM!Health Association of New York
Faith Pharmacy iHealth
State (CHCANYS)
Bronx Community Health
Network Family Health Centers at Institute for Family Health
Community Health Center
NYU Langone
of Buffalo
BronxCare Health Iris House
Integrated Services Family Health Network of
Community Health Center
System, Inc. Central New York, Inc. Jericho Road Community
of Richmond
Health Center
Brooklyn Plaza Medical Finger Lakes
Community Health
Center, Inc. Community Health Jordan Health
Initiatives, Inc.
Brownsville Community FPWA Korean Community
Community Health IPA
Development Corp. Services of Metropolitan
GMHC New York
Community Healthcare
Callen-Lorde Network
God’s Love We Deliver Latino Commission on
Care for the Homeless AIDS (LCOA)
ConnextCare
Grand Concourse Seven
Casita Maria, Inc. Day Adventis Church Latinos for Healthcare
Cornerstone Family
Equity
Healthcare
Catholic Charities Haitian-American
AIDS Services, dba Community Coalition, Inc. Legal Action Center
Covenant House New York
Catholic Charities Care
Coordination Services Harlem United Long Island Center for
Damian Family Care
Independent Living, Inc.
Centers, Inc.
(LICIL)
Long Island FQHC, Inc. NEXT Harm Reduction Reverend Kirsten John Therapeutic Community
Foy, Minister and the Association of New York
Make the Road New York Nonprofit Finance Fund President and Founder (TCA)
of the Arc of Justice
Metro Community Health North Country Family TOUCH-Together Our
Centers, Inc. Health Center RiverStone Consulting Unity Can Heal

Mosaic Health NYC Health + Hospitals Robin Hood Foundation Treatment Action Group
/Gotham Health
Mount Sinai Rochester Area Task Trillium Health
NYU Langone Health Force on AIDS
Mount Vernon Trinity Pentecostal House
Neighborhood Health Oak Orchard Health Russell Institutional of Prayer
Center, Inc. CME Church
ODA Primary Health Truth Pharm, Inc.
NAACP, Hazel Dukes, Care Network, Inc. Ryan Chelsea-Clinton
President of NAACP New UNION
York State Conference Open Door Family Ryan Health
Medical Center Union Community
National Black Leadership Ryan White Clinics for Health Center
Commission on Health, Our Wellness Collective 340B Access
Inc. (Black Health) Unity Fellowship of
Peer Network Of New York Safety Net Association Christ Church NYC
National Working of Primary Care
Positive Coalition Planned Parenthood Affiliated Providers, Inc. Universal Primary Care
Empire State Acts (SNAPCAP)
Neighborhood Upstate Community
Health Center of Positive Health Project SBPA Health Collaborative
Western New York
Pride Center of Staten Settlement Health Urban Health Plan, Inc.
NEW Pride Agenda Island
Southern Tier AIDS Urban Pathways
New York #insulin4all Primary Care Development Program
Corporation (PCDC) Vera House, Inc.
New York Association of St. Ann’s Corner of
Alcoholism and Substance Progressive Doctors Harm Reduction VOCAL-NY
Abuse Providers (ASAP)
Project Renewal, Inc. St. Joseph’s Vocational Instruction
New York Harm Reduction Rehabilitation Center Project Community
Project Safety Net NY Services, Inc. (VIP
Educators (NYHRE)
Sun River Health Community Services)
Retail, Wholesale, and
New York Immigration
Department Store Union Syracuse Community Washington Heights
Coalition (NYIC)
(RWDSU) Health Center Corner Project (WHCP)
New York State Nurses
RevCore Recovery Center The Chautauqua Center Whitney Young Health
Association (NYSNA)
Reverend Dr. Johnnie The Lesbian, Gay, Williams Institutional
New York Transgender
Green, President of MPAC Bisexual & Transgender CME Church, NYC
Advocacy Group (NYTAG)
and Sr Pastor of Mt. Nebo Community Center
Baptist Church of Harlem