The purpose of this memo is to announce an exception to the Pre-Exposure Prophylaxis (PrEP) Assistance Program (PrEP-AP) clients with confidentiality concerns client type and release the updated Confidentiality Concern Enrollment Worker Verification Affidavit. Moving forward, insured individuals who are unable to access non-occupational Post Exposure Prophylaxis (nPEP) through a provider in their health plan's network will be eligible to enroll in PrEP-AP as clients with confidentiality concerns under a Temporary Access Period (TAP).
In accordance with Health and Safety Code 120972.d PrEP-AP allows enrollment workers to enroll clients into PrEP-AP as clients with confidentiality concerns if they have health insurance through a parent, spouse, or registered domestic partner, and have confidentiality concerns using their own insurance. Clients enrolled as PrEP-AP clients with confidentiality concerns can access PrEP or nPEP related care through a PrEP-AP Clinical Provider and are exempt from providing proof of income and co-enrolling in a pharmaceutical assistance program such as Gilead Advancing Access®.
PrEP-AP is aware that some providers will not prescribe PrEP or post exposure prophylaxis (PEP) medications to clients because of lack of familiarity with PrEP/PEP medications and prescribing guidelines. In these scenarios, providers can be directed to the following Centers for Disease Control and Prevention (CDC) resources regarding PrEP and PEP:
Patients and their advocates also have the following options when a provider in their health plan will not prescribe PrEP or PEP medications:
- File a formal complaint against the provider
- Contact the local Ombudsman
- Locate a provider within their network who is willing to provide PrEP or PEP care
Due to the time sensitivity for accessing PEP medications after a potential HIV exposure, PrEP-AP will allow insured individuals to enroll as PrEP-AP clients with confidentiality concerns if their in-network provider will not prescribe nPEP.
Confidentiality Concern Enrollment Worker Verification Affidavit
The Confidentiality Concern Enrollment Worker Verification Affidavit has been updated to include verification that an insured individual has sought nPEP treatment from an in-network provider and the provider would not prescribe the necessary medication. When completing the Confidentiality Concern Enrollment Worker Verification Affidavit please select the appropriate scenario the affidavit is verifying.
Enrollment in ADAP Enrollment System (AES)
When enrolling clients who are not able to access nPEP through their in-network provider as PrEP-AP clients with confidentiality concerns in AES, you must place the client on a TAP. The Confidentiality Concern Enrollment Worker Verification Affidavit must be uploaded in the AES when enrolling a client with confidentiality concerns. Please note, enrollment workers who are found to enroll clients as a client with confidentiality concerns without properly verifying that the client meets the criteria or enrolls them as a client with confidentiality concerns to bypass other program requirements, may result in the termination or suspension of my enrollment worker privileges.
OA reviews all applications with confidentiality concerns for eligibility. Clients who are incorrectly enrolled into PrEP-AP with confidentiality concerns that do not meet eligibility requirements directly impact the available funding for clients that do meet eligibility requirements. Incorrectly enrolling a client into PrEP-AP with confidentiality concerns that does not meet eligibility requirements violates health and safety code and impacts program expenditures for PrEP-AP.
If you have any questions regarding this new PrEP-AP requirement, or if you have any questions regarding the information provided in this memo, e-mail the PrEP-AP inbox at PrEP.Support@cdph.ca.gov.
Sharisse Kemp, MSW
ADAP Branch Chief
California Department of Public Health