HIV/HCV Co-Infection Watch Q4: October 2026
The HIV/HCV Co-Infection Watch is a project of the Community Access National Network (CANN) designed to research, monitor, and report on HIV and Hepatitis C (HCV) co-infection in the United States. The October 2026 Watch includes timely updates herein. To read the project disclaimer and/or methodology, CLICK HERE.
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TABLE OF CONTENTS:
1. FINDINGS
The following is a summary of the key findings for October 2026:
AIDS Drug Assistance Programs:
The Watch tracks 59 state and territorial AIDS Drug Assistance Programs (ADAPs), including those of the freely associated states of Micronesia, the Marshall Islands and Palau. Forty-four (44) offer some form of coverage for hepatitis C (HCV) treatment; thirty-nine (39) cover at least one direct-acting antiviral (DAA) regimen, the current standard of care; and thirty-seven (37) cover at least one pangenotypic agent, meaning a regimen FDA-approved for all six major HCV genotypes (Epclusa or its authorized generic, Mavyret, or Vosevi). Five (5) programs — Alaska, Rhode Island, South Carolina, Micronesia and Puerto Rico — are scored as Basic Coverage only; Alaska and Micronesia publish no formulary, and their Basic Coverage rests on values carried from the prior edition. Fifteen (15) show no coverage (see Section 2). Twenty (20) programs cover Vosevi, the principal salvage regimen after DAA failure. Counted across all 59 programs, the October lists show 44 programs with some coverage, 41 covering a DAA, 39 covering a pangenotypic agent and 23 covering Vosevi. Three programs changed published coverage: California and Puerto Rico dropped the discontinued Zepatier from their ADAP formularies, and Maine dropped Vosevi. Other moves reflect the Watch's reading of documents rather than program changes: Puerto Rico requires a fibrosis test for every DAA, and Rhode Island requires abstinence or treatment-program participation for Mavyret, both scored as no coverage; Minnesota's drug lookup ties Sovaldi, Harvoni, Epclusa and both authorized generics to its non-preferred criteria; Michigan's mandatory generic program excludes brand Harvoni and Epclusa; and authorized generics listed by generic name are scored as covered.
A state-by-state Drug Formulary breakdown is included in the October 2026 Updates, with drug-specific maps in Figures 1 – 10.
Medicaid Programs:
Of the 56 state and territorial Medicaid programs (Micronesia, the Marshall Islands and Palau have no United States Medicaid program), all 50 states and the District of Columbia list at least one hepatitis C DAA on their preferred drug lists. As the Watch scores coverage, fifty-one (51) programs cover at least one DAA, and each of those covers a pangenotypic agent. The five that do not are Maryland, which requires a fibrosis staging test before approving any DAA for chronic hepatitis C; West Virginia, which requires one for every DAA request; Puerto Rico, which requires fibrosis documentation for both of its DAAs; and American Samoa and the Northern Mariana Islands, where no governing formulary could be confirmed. Mavyret is covered in 48 states and D.C. and preferred in 47 and D.C. (Louisiana covers it as non-preferred); generic Epclusa is covered in 42 states and D.C. and preferred in 39 and D.C. (Michigan, Montana and Virginia cover it as non-preferred).
Two states eased access to hepatitis C treatment this quarter: South Carolina removed prior authorization from Mavyret, its preferred hepatitis C drug, effective August 1, 2026, ending its status as a state with no scored coverage, and North Dakota removed prior authorization from Mavyret and generic Epclusa, along with its sobriety clause and other hepatitis C criteria, effective October 1, 2026. Oklahoma now lists generic Epclusa with Mavyret as a preferred DAA with no prior authorization. Three changes narrowed access: South Carolina moved Epclusa, generic Epclusa and Vosevi to non-preferred; North Carolina moved Vosevi to non-preferred; and Colorado, Utah and two UnitedHealthcare plans (Hawaii QUEST and New Jersey FamilyCare) removed the discontinued Zepatier. Nevada eased access earlier, removing its prescriber-specialty requirement effective July 6, 2026 (MTL 19/26). No state Medicaid program's written criteria make sobriety a condition of initial treatment; six states require a substance-use assessment, counseling or attestation, and Kentucky requires patients with recent substance use to show through laboratory testing that they are not using before retreatment. A complete state-by-state PDL breakdown, with sources, is included in the October 2026 Updates, with drug-specific maps in Figures 11 – 20.
Patient Assistance Programs:
Good Days is the only charitable hepatitis C fund accepting applications this quarter, and it now requires government-sponsored insurance, so commercially insured patients other than federal employees no longer qualify for any open charitable hepatitis C fund in this section. Manufacturer co-pay cards exclude people in Medicare, Medicaid and other federal health care programs, who rely on charitable funds or on free-drug programs such as AbbVie's myAbbVie Assist, which accepts people with Medicare.
Harm Reduction Programs:
Syringe Services Programs: Forty-four (44) states, the District of Columbia and one (1) territory, Puerto Rico, have at least one syringe services program (SSP) operating, regardless of legality; Alabama, Kansas, Mississippi, Nebraska, South Dakota, and Wyoming do not. Idaho joins the list this edition, the U.S. Virgin Islands leaves it, and Guam is listed without an SSP. See the Harm Reduction Program Notes on SAMHSA's April 2026 funding limits and Oklahoma's expired syringe-program law.
Expanded Naloxone Access: All fifty (50) states, the District of Columbia, Puerto Rico and Guam allow pharmacies to dispense naloxone without an individual prescription through statute, standing order or pharmacist protocol (LAPPA, January 2025). Since January 1, 2026, CalRx's over-the-counter naloxone costs $19 per twin pack for individuals, who also pay shipping, and for California organizations buying directly from manufacturer Amneal; qualifying organizations get it free through the state's Naloxone Distribution Project (Office of the Governor, December 19, 2025; CalRx fact sheet, January 5, 2026; CalRx Naloxone store).
Safe Consumption Sites: Two (2) states have operating safe consumption sites: New York, where OnPoint NYC operates two sites without state authorization (NYC Health Department opioid settlement funds report, September 3, 2026), and Rhode Island, whose state-regulated center opened in January 2025 and is authorized to March 1, 2028 (R.I. Gen. Laws § 23-12.10-6). Vermont authorized overdose prevention centers in 2024, but Burlington's center had not opened as of October 7, 2026.
Updated Paraphernalia Laws: Forty-seven (47) states and the District of Columbia exempt possession of fentanyl test strips from paraphernalia penalties for at least some people. In six of those states (Connecticut, Kentucky, Louisiana, Maryland, Montana and Tennessee) and the District of Columbia, the exemption depends on who holds the strips or how they are used (LAPPA, September 2025). Iowa, North Dakota and Texas still classify testing equipment as paraphernalia with no exception; North Dakota and Texas are new to that list (see the Harm Reduction Program Notes).
Good Samaritan Laws: Every state and the District of Columbia now has an overdose Good Samaritan law; Kansas (2024) and Wyoming (2025) were the last to enact one (LAPPA, July 2025). This edition sorts those laws into three tiers. An expanded law protects both the person who calls for help and the person who overdosed from arrest, as well as from charges and prosecution, for both drug possession and paraphernalia; a limited law offers some protection but falls short of that standard. Twenty-two (22) states have expanded laws, and the other twenty-eight (28) states and the District of Columbia have limited laws; six states join the expanded tier and nine move to the limited tier (see the Harm Reduction Program Notes). Among the territories, Puerto Rico's law is expanded, the Northern Mariana Islands' law is limited, and American Samoa, Guam and the U.S. Virgin Islands have none.
Prescriber Education: Forty (40) states require, through legislative action or regulatory or licensing bodies, that physicians who prescribe controlled substances complete training on safer controlled-substance, opioid, or pain-management prescribing. Ten states and the District of Columbia do not: Idaho, Indiana, Minnesota, Mississippi, Missouri, Montana, North Dakota, Ohio, South Dakota, and Virginia. The drop from July's 48 states and the District of Columbia reflects the Watch's definition applied to each state's current statute or board rule, not a policy change since July. Requirements expired in Indiana (July 1, 2025) and Minnesota (January 1, 2023), and Mississippi's board replaced its requirement with federal MATE Act training on substance use disorder, which the Watch does not count (rule filed final January 27, 2026. The MATE Act (21 U.S.C. § 823(l)) separately requires DEA-registered practitioners other than veterinarians to complete eight hours of one-time substance use disorder training or an equivalent qualification. State lists and maps (Figures 21–26) follow in the October 2026 Updates.
2. AIDS DRUG ASSISTANCE PROGRAMS (ADAPs) & HCV THERAPIES
Of the 59 state and territorial ADAPs the Watch tracks, 15 do not offer any coverage for HCV drug therapies: GA, KS, KY, MO, NM, OH, TX, VT, V.I., UT, GU, AS, MP, MH, and PW. Nine of them publish a formulary or exclusion policy that excludes, suspends, or omits HCV medications; the other six (UT, GU, AS, MP, MH, and PW) publish no formulary the Watch could locate. The Watch cites the National Alliance of State and Territorial AIDS Directors (NASTAD) ADAP Formulary Database (coverage as of January 1, 2026) for context only; every coverage value comes from a program's own documents or statements. The data presented are current as of October 27, 2026.
October 2026 Updates:
Basic HCV Medications
States with Basic HCV Medications Coverage: AL, AK, AZ, AR, CA, CO, CT, DE, FL, HI, IL, IN, IA, LA, ME, MD, MA, MI, MN, NE, NV, NH, NJ, NY, NC, ND, OK, PA, RI, SC, SD, VA, WA, WV, WI, WY, D.C.
States without Basic HCV Medications Coverage: GA, ID, KS, KY, MS, MO, MT, NM, OH, OR, TN, TX, UT, VT
States with No Information on Basic HCV Medications Coverage: None
Territories with Basic HCV Medications Coverage: F.S.M., P.R.
Sovaldi
States with Sovaldi Coverage: AZ, CA, CO, HI, IL, IN, IA, LA, ME, MD, MA, NE, NV, NJ, ND, OK, SD, VA, WA, WI, WY, D.C.
States without Sovaldi Coverage: AL, AK, AR, CT, DE, FL, GA, ID, KS, KY, MI, MN, MS, MO, MT, NH, NM, NY, NC, OH, OR, PA, RI, SC, TN, TX, UT, VT, WV
States with No Information on Sovaldi Coverage: None
Territories with Sovaldi Coverage: None/Unknown
Harvoni
States with Harvoni Coverage: AZ, AR, CA, CO, CT, DE, FL, HI, ID, IL, IN, IA, LA, ME, MD, MA, MS, MT, NE, NV, NJ, NC, ND, OK, OR, SD, TN, VA, WA, WI, WY, D.C.
States without Harvoni Coverage: AL, AK, GA, KS, KY, MI, MN, MO, NH, NM, NY, OH, PA, RI, SC, TX, UT, VT, WV
States with No Information on Harvoni Coverage: None
Territories with Harvoni Coverage: None/Unknown
Zepatier — Merck discontinued Zepatier effective December 1, 2025; this is the last edition in which the Watch tracks it.
States with Zepatier Coverage: AL, AZ, AR, CO, FL, HI, IL, IA, LA, ME, MD, MA, MI, MS, MT, NE, NV, NJ, NY, NC, ND, OR, PA, SD, VA, WA, WV, WI, WY, D.C.
States without Zepatier Coverage: AK, CA, CT, DE, GA, ID, IN, KS, KY, MN, MO, NH, NM, OH, OK, RI, SC, TN, TX, UT, VT
States with No Information on Zepatier Coverage: None
Territories with Zepatier Coverage: None/Unknown
Epclusa
States with Epclusa Coverage: AZ, AR, CA, CO, CT, FL, HI, ID, IL, IN, IA, LA, ME, MD, MA, MS, MT, NE, NV, NJ, ND, OR, PA, SD, TN, VA, WA, WI, WY
States without Epclusa Coverage: AL, DE, GA, KS, KY, MI, MN, MO, NH, NM, NY, NC, OH, OK, RI, SC, TX, UT, VT, WV, D.C.
States with No Information on Epclusa Coverage: AK
Territories with Epclusa Coverage: None/Unknown
Vosevi
States with Vosevi Coverage: CA, CO, CT, FL, HI, ID, IL, IN, IA, LA, MD, MA, NE, NV, NJ, ND, SD, TN, WA, WY
States without Vosevi Coverage: AL, AZ, AR, DE, GA, KS, KY, ME, MI, MN, MS, MO, MT, NH, NM, NY, NC, OH, OK, OR, PA, RI, SC, TX, VT, VA, WV, WI, D.C.
States with No Information on Vosevi Coverage: AK, UT
Territories with Vosevi Coverage: None/Unknown
Pegasys
States with Pegasys Coverage: AL, CA, CT, DE, HI, IL, IA, LA, ME, MD, MA, MI, MN, NE, NV, NH, NJ, NY, NC, ND, OK, PA, RI, SD, WA, WV, WI, WY, D.C.
States without Pegasys Coverage: AZ, AR, CO, FL, GA, ID, IN, KS, KY, MS, MO, MT, NM, OH, OR, SC, TN, TX, UT, VT, VA
States with No Information on Pegasys Coverage: AK
Territories with Pegasys Coverage: None/Unknown
Mavyret
States with Mavyret Coverage: AL, AR, CA, CO, CT, FL, HI, ID, IL, IN, IA, LA, ME, MD, MA, MI, MN, MS, MT, NE, NV, NH, NJ, NY, NC, ND, OR, PA, SD, TN, VA, WA, WV, WI, WY, D.C.
States without Mavyret Coverage: AZ, DE, GA, KS, KY, MO, NM, OH, OK, RI, SC, TX, VT
States with No Information on Mavyret Coverage: AK, UT
Territories with Mavyret Coverage: None/Unknown
Harvoni (generic)
States with Harvoni (generic) Coverage: AZ, CA, CO, CT, DE, FL, HI, ID, IL, IN, IA, LA, ME, MD, MA, MI, MS, MT, NE, NV, NH, NJ, NC, ND, OK, OR, SD, TN, VA, WA, WI, WY, D.C.
States without Harvoni (generic) Coverage: AL, AR, GA, KS, KY, MN, MO, NM, NY, OH, PA, RI, SC, TX, VT, WV
States with No Information on Harvoni (generic) Coverage: AK, UT
Territories with Harvoni (generic) Coverage: None/Unknown
Epclusa (generic)
States with Epclusa (generic) Coverage: AZ, CA, CO, CT, FL, HI, ID, IL, IN, IA, LA, ME, MD, MA, MI, MS, MT, NE, NV, NH, NJ, ND, OR, PA, SD, TN, VA, WA, WI, WY
States without Epclusa (generic) Coverage: AL, AR, DE, GA, KS, KY, MN, MO, NM, NY, NC, OH, OK, RI, SC, TX, VT, WV, D.C.
States with No Information on Epclusa (generic) Coverage: AK, UT
Territories with Epclusa (generic) Coverage: None/Unknown
State and Territory ADAP Formulary Notes:
Arizona
The formulary (updated 02/13/2026) still records "02/13/2026 All AbbVie products removed from Formulary." Each covered DAA row asks the prescriber to "submit all data elements contained within the HCV patient registry," which the program's HIV/HCV Registry information sheet lists; its ADAP FAQ states that hepatitis C medications "are available without a prior authorization." Policy Clarification Memorandum 19-01 (October 18, 2019) states that ADAP collects the registry "to track hepatitis C treatment" and sets no prescriber, liver-disease or sobriety restriction, and the Watch does not score the registry as a barrier.
California
California ADAP's current Detailed Formulary PDL listing (Effective Date: October 22, 2026) contains no Zepatier row, and the program's Prime Therapeutics page states that "NDCs not listed are not currently covered," although the Formulary Overview (October 6, 2026) still names elbasvir/grazoprevir. The other nine tracked items remain covered, including both authorized generics, with no prior authorization flag.
Colorado
Offers five coverage options — Standard ADAP, HIV Medical Assistance Program (HMAP), Bridging the Gap Colorado (BTGC), HIV Insurance Assistance Program (HIAP), and Supplemental Wrap Around Program (SWAP) — and a drug is listed as covered when at least one of them covers it. The Standard ADAP Formulary (effective July 18, 2025) also applies to HIAP and SWAP, per its header; the program's State Drug Assistance Program Application & Recertification Form states that assistance is "contingent on state and federal funding."
Georgia
The hepatitis C program remains closed. The formulary (Revised: September 2026) states on page 4: "Georgia ADAP Hepatitis C Program is currently on HOLD until future funding is available. Please utilize Patient Assistance Programs (PAP's) for Hepatitis C medications."
Hawaii
The HIV Drug Assistance Program Formulary (October 2026) repeats: "Treatment slots for HCV direct-acting antivirals may be limited. Prescriber or pharmacy must call HDAP for slot."
Idaho
The formulary (Effective Date: May 12, 2025) leaves the Criteria/Notes column blank for Mavyret, Harvoni, Epclusa and Vosevi. A hepatitis C prior authorization form (Revision Date: 11/11/2022) in the folder the formulary points to it asks for a fibrosis score without marking it required or setting a minimum, and limits Vosevi to "treatment failure requests only," which restates Vosevi's FDA labeling; the Watch scores neither as a barrier.
Illinois
The formulary (Effective 1/1/2026) states that "ALL PRESCRIPTION DRUGS are covered with noted prior authorizations and exclusions" and names no hepatitis C drug in either list.
Kansas
The formulary (Revised October 2018) lists no hepatitis C drug. The Kansas Medical Assistance Program coverage search returned "not covered" for every hepatitis C drug checked under the ADAP full-benefits plan on October 26, 2026.
Louisiana
ADAP (Louisiana Health Access Program – LA HAP) offers coverage for uninsured clients (Louisiana Drug Assistance Program – L-DAP) and insured clients (Health Insurance Program – HIP) and moved its pharmacy benefit manager from Ramsell to ScriptGuideRx (SGRX) on May 1, 2026 (LA HAP bulletin, May 2026). The Policies and Procedures Manual (Revised 05/01/2026), section 3.1, states that "Prior Authorization from PBM is required to obtain Hepatitis C medications"; the linked request form asks only for the diagnosis, genotype, prior treatment, cirrhosis history and a recent viral load, which the Watch does not score as a barrier. The manual also describes a hepatitis C treatment program for co-infected clients with full Medicaid that is "capped at 45 participants at a time." For insured clients, LA HAP pays cost-shares through its pharmacy benefit manager, not HIP, only for drugs on the primary insurer's formulary (sections 2.4 and 3.2.1).
Maine
The September 2026 ADAP formulary no longer lists Vosevi. Prior authorization flags on Sovaldi, Harvoni, generic Harvoni and Mavyret tablets are unchanged; Maine publishes no ADAP hepatitis C criteria and its list has no preferred or non-preferred tier, so the Watch does not score a flag alone as a barrier (Minnesota differs because its lookup ties prior authorization to published non-preferred criteria).
Michigan
Michigan ADAP covers generic Harvoni and generic Epclusa. The formulary (Last Updated: 1/1/2026) marks both brands with an asterisk, defined as "the generic equivalent is available," under a "MANDATORY GENERIC PROGRAM" that "excludes coverage of brand-name drugs with FDA approved generic equivalents," and the Watch scores brand Harvoni and brand Epclusa as not covered. The program's page states that "MIDAP has removed the prior authorization for hepatitis C medications." Sovaldi and Vosevi are not on the formulary. The generic and brand values reflect the Watch's standard for generic listings (see Cross-Program Notes), not a change in the program's policy.
Minnesota
The program's own drug lookup, queried October 27, 2026 under "MN ADAP - HH," shows Zepatier and Vosevi as not covered and lists Sovaldi, Harvoni, Epclusa, generic Harvoni and generic Epclusa as "Non-Preferred" with "Clinical PA Req Yes," which, the lookup states, "require prior authorization and must meet the non-preferred drug prior authorization criteria." Minnesota's hepatitis C criteria (January 2025) approve a non-preferred drug only when the patient is "NOT a candidate for the preferred drugs" and "clinically significant drug interactions with the preferred drug cannot be mitigated," with no route through prior treatment or prescriber justification, and the Watch scores the five as no coverage. Mavyret, Pegasys and ribavirin are preferred without prior authorization. These values changed because the Watch used a new source, not because the program changed its policy; the Department of Human Services page the July edition relied on, which described the formulary as open, is no longer posted.
Missouri
Covers no hepatitis C medication and publishes no drug list. The Department of Health and Senior Services' Care & Case Management page (viewed October 28, 2026) states: "Effective June 1, 2026, the Missouri Ryan White Part B program will remove non-HIV medications from its AIDS Drug Assistance Program (ADAP) formulary." Its Limitations and Exclusions document (effective April 2026) excludes non-antiretroviral medications not on the current formulary.
New Jersey
The AIDS Drug Distribution Program publishes no drug list. The Watch's values rest on the program's own statement in a July 27, 2026 telephone call that all hepatitis C medications are covered without prior authorization.
New Mexico
New Mexico ADAP covers no hepatitis C medication through the program it runs directly. The HIV Services Program Policies and Procedures Manual (revised August 2022), page 4, states for the ADAP Bridge: "As per the Enhanced Formulary, HCV medications are not covered by this process." The 2018 Enhanced Formulary policy it cites is no longer posted. For insured clients, the Insurance Assistance Program pays co-pays only for medications on the state's ADAP Formulary (page 28), which the manual defines as an "Enhanced Formulary" with no specific list under which "any FDA-approved medications could be considered for coverage" (page 4). No posted document says whether the program pays hepatitis C co-pays for insured clients.
Oklahoma
The formulary (FY2016, dated December 14, 2015), the most recent the program posts, lists ribavirin, pegylated interferons, Sovaldi and Harvoni and no later DAA. Harvoni appears with its generic name, ledipasvir/sofosbuvir, so the Watch scores the authorized generic as covered, although the formulary predates it. Both hepatitis C headings carry the note "(requires prior contact to pharmacy)." Because the program's eligibility criteria require "a physician's prescription(s) for the drugs listed on the HDAP formulary," the Watch scores the other DAAs as not covered rather than No Information.
Pennsylvania
The Special Pharmaceutical Benefits Program covered drug list (Effective 09-01-26) covers Epclusa, generic Epclusa, Mavyret, Zepatier, Pegasys and ribavirin. Sovaldi, Harvoni, generic Harvoni and Vosevi are not listed.
Puerto Rico
Puerto Rico ADAP's formulary (Anejo B, "revisado: 1 de julio de 2026") no longer lists Zepatier. The Department of Health's hepatitis C prior authorization procedure (revised June 15, 2022), page 5, requires each request to include "prueba de fibrosis (Fibrotest, FibroScan u otra prueba de fibrosis)," so under the Watch's fibrosis rule every DAA on Anejo B — Epclusa and Harvoni, each with "o GENÉRICO BIOEQUIVALENTE," Mavyret, Sovaldi and Vosevi — is scored as no coverage. The procedure has not changed since 2022; the DAA values changed because the Watch used a new source, not because the program changed its policy. Ribavirin remains covered without prior authorization.
Rhode Island
The formulary (October 2026) lists Mavyret as its only DAA, with Pegasys and ribavirin. The state's HIV/AIDS providers page also links "Prior Authorization Guidelines: Medications for Treatment of Hep C" (effective September 25, 2017), which limit prescribing to specialists and other physicians the program approves, and require patients with "current or past significant alcohol or intravenous drug abuse" to be "actively participating in a clinician monitored treatment program or abuse free for a minimum of 6 months." The monitoring may take place in the treating clinician's office, with attestation, but a patient who is not abstinent must still be in a treatment program, and under the Watch's sobriety rule Mavyret is scored as no coverage; Pegasys and ribavirin remain covered. The guidelines' statement that the patient contract is "not an eligibility screen for denying HCV drugs" applies to the contract, not to this clause. The Watch located these guidelines this quarter; the program's policy has not changed since 2017.
Texas
The Texas HIV Medication Program formulary (Effective September 1, 2025) lists no hepatitis C drug; the program's guidelines (last updated April 2026) describe coverage of medications "for the treatment of HIV."
U.S. Virgin Islands
The Watch located the territory's ADAP formulary this quarter, hosted by its pharmacy benefit manager ("US Virgin Islands AIDS Drug Assistance Formulary, Revised February 2024"). It lists none of the ten tracked hepatitis C items. The July edition recorded that the territory published no formulary.
Virginia
Virginia ADAP's formulary (Effective 6/1/2026, Version 3.2026) lists Zepatier, Mavyret, Harvoni, ribavirin, Sovaldi and Epclusa, each under its generic name, under "HEPATITIS C TREATMENT" with the note "Requires an Hepatitis C/HIV Treatment Assistance Program Application"; Vosevi and peginterferon are not listed. The program's HCV/HIV Treatment Assistance application (Rev.12/2017, p.2) excludes every client with decompensated cirrhosis: 'Does client have decompensated cirrhosis? ... (If Yes, client is excluded at this time)'. Such patients cannot get any hepatitis C drug through Virginia ADAP, including Epclusa and its generic, labeled with ribavirin for decompensated cirrhosis in every genotype, and Harvoni and its generic, labeled for it in genotype 1. Because the exclusion is limited to decompensated cirrhosis, it does not change a coverage score: the Watch scores every hepatitis C drug on the formulary, and both authorized generics, as covered.
Cross-Program Notes
Salvage therapy remains the narrowest coverage of any tracked drug. Twenty (20) of 59 programs cover Vosevi, down from twenty-three (23) on the July data: Maine's formulary no longer lists it, Minnesota's lookup shows it not covered, and Puerto Rico's fibrosis-test requirement applies to it. Elsewhere, clients who failed an NS5A-containing regimen have a listed alternative only if they have genotype 1, did not also take an NS3/4A protease inhibitor, and their program covers Mavyret: the VA's Treatment Considerations (updated March 18, 2021) list Mavyret for 16 weeks in that case, a use the Mavyret prescribing information (DailyMed, August 7, 2026) limits to genotype 1, and list only Vosevi after NS5A failure in genotypes 2, 3 and 4. Clients whose earlier regimen contained sofosbuvir but no NS5A inhibitor, the other group Vosevi is labeled for (genotypes 1a and 3), can take Mavyret where their program covers it (genotypes 1 through 4).
Generic listings. Where an ADAP formulary lists a drug by its generic name, the Watch scores the authorized generic as covered; where a program excludes brand-name drugs with generic equivalents, the brand is scored as not covered. On this basis, generic Harvoni and generic Epclusa are scored as covered in Arizona, Hawaii, Idaho (whose formulary states that "IDHW mandates the use of generic products whenever possible") and Virginia, each cited in its note above, and in Indiana (formulary, Rev. 1/26/2024: drugs listed by ingredient name, with "Generics are preferred. Branded medications must be pre-approved prior to each fill by IDOH") and Wisconsin (formulary P-02760, September 2026: Harvoni and Epclusa listed by generic name first); generic Harvoni is scored as covered in the District of Columbia (Pharmacy Benefits Program Formulary) and Oklahoma ADAPs; Michigan's brands are scored as not covered; and Arkansas ADAP's generics are scored as not covered because its closed formulary (revised October 24, 2023) lists Harvoni and Epclusa by brand name only.
Open Formularies
Programs identified as operating open formularies: CA, IL, IA, MA, NE, NH, NJ, NM, ND, OH, OR, WA, WY
Verified Open Formulary
California
Operates an open formulary administered by Prime Therapeutics. Per the program: "OA has transitioned ADAP to an open formulary model. This means all FDA-approved medication will be included (with some exceptions due to safety concerns or cost)." No hepatitis C drug appears on the list of medications requiring prior authorization (effective September 1, 2026); see the California note above for Zepatier.
Open Formulary with HCV Carveout
New Hampshire
The NHADAP preferred drug list (effective November 1, 2026) is unchanged: "Trial and failure of 1 Preferred product required prior to Non-Preferred products." Preferred drugs are ribavirin, Pegasys, Mavyret, generic Harvoni and generic Epclusa; Sovaldi, Harvoni, Zepatier, Epclusa and Vosevi are non-preferred and therefore scored as no coverage. Every hepatitis C product carries the list's double asterisk, which "Indicates when additional Prior Approval is required for the therapeutic class, even when using a preferred product." The program publishes no hepatitis C criteria; its prior authorization form (Effective Date: 12/04/2024) asks for clinical history and whether a specialist is treating or was consulted or the prescriber has completed hepatitis C continuing education, which the Watch does not score as a barrier.
New Mexico
The program's "Enhanced Formulary" has no drug list, and hepatitis C drugs are excluded from its ADAP Bridge, the direct-dispensing option for uninsured clients (see the New Mexico note above).
North Dakota
The formulary (7-2023) states: "ND ADAP reimburses HIV-injectable and Hepatitis C medication copays/deductibles/co-insurance only. Exceptions will be addressed on an individual basis." The program's standards (August 16, 2023) name the exceptions: people not eligible for health coverage, people in a transition period, and people whose primary coverage denies the medication. The state's drug lookup flags every hepatitis C drug "PA Required" under the ADAP plan without published criteria, and the Watch carries the prior edition's values.
Ohio
The OHDAP formulary (effective May 1, 2024) lists among its exclusions "Hepatitis C Treatment (e.g., direct-acting antivirals)."
Oregon
CAREAssist's Preferred Network formulary (effective August 1, 2026) keeps Section B closed: "Hepatitis C drugs when insurance denies or if client has no insurance (coverage includes these medications ONLY)." It covers glecaprevir/pibrentasvir, ledipasvir/sofosbuvir, velpatasvir/sofosbuvir and elbasvir/grazoprevir under the heading "Prior Authorization (PA) REQUIRED DRUGS," and states that these drugs "will only be approved after the PA criteria is FULLY met." Its asterisk note now reads "*PA required ONLY for patients whose primary insurance denies covering the medication," where the October 1, 2024 edition also named uninsured patients, but uninsured clients still go through prior authorization: the program's Hepatitis C Requirements for Coverage (undated) list "CAREAssist clients who are uninsured" first among those eligible. The Bridge formulary (effective August 1, 2026) states: "NO HEP C COVERAGE FOR TREATMENT NAÏVE PATIENTS."
Wyoming
The ADAP formulary (effective March 2018), now posted only on the pharmacy benefit manager's site, requires prior authorization for hepatitis C treatment medications, an application for prior authorization from the client's insurance plan, and a WY ADAP Hepatitis C Treatment checklist signed by the provider and client. The same page states that drugs the program provides "must not exceed $50,000 per year / $5,000 per month / $3400 per claim per client. Claims beyond that cap must be pre-authorized." The checklist is not published; the Watch carries the July values because the formulary is unchanged.
3. MEDICAID PROGRAMS & HCV THERAPIES
All 50 states and the District of Columbia list at least one hepatitis C direct-acting antiviral on their preferred drug lists. The Watch measures coverage against best practices for ending the hepatitis C epidemic: a person diagnosed with HCV should be able to begin curative treatment promptly, with as few visits, tests and approvals as possible, so a rule that adds a step between diagnosis and treatment is scored as a barrier even when some patients can clear it. A requirement to fail a preferred drug first, a required fibrosis test, a sobriety period, a prior-treatment requirement narrower than the drug's FDA label, a prior authorization with no published standard, a case-by-case review, or a medical-necessity determination left to the insurer scores as no coverage. Where a prior authorization standard is unpublished but the governing document is unchanged since July, the July value carries (the District of Columbia, Guam and the U.S. Virgin Islands). Three of the 56 programs have no scored coverage of any of the ten tracked drugs: Maryland, which requires fibrosis staging for every DAA prescribed for chronic hepatitis C and publishes no standard for ribavirin or Pegasys, and American Samoa and the Northern Mariana Islands, where no governing formulary could be confirmed. West Virginia and Puerto Rico cover ribavirin only. The data presented are current as of October 27, 2026.
Fibrosis scoring. The Watch treats any requirement to document a fibrosis score or stage before treatment as a barrier to care, including a required assessment of cirrhosis that a physical examination can satisfy, whether or not the state sets a minimum stage and whether the score comes from a blood-based index such as FIB-4 or APRI, from elastography such as FibroScan, or from biopsy. A score is not needed to begin curative treatment under a test-and-treat model, and a scoring requirement can mean the patient must come back for a visit they might otherwise not return for. Earlier editions treated only minimum-score requirements as a barrier; beginning with the October 2026 edition, any required score counts. A fibrosis field that appears on a form but is not marked required, or that accepts "unknown," is not treated as a requirement.
October 2026 Updates:
Basic HCV Medications
States with Basic HCV Medications Coverage: AL, AK, AZ, AR, CA, CO, CT, DE, FL, GA, HI, IL, IN, IA, KS, KY, LA, ME, MA, MI, MN, MS, NE, NV, NH, NJ, NM, NY, NC, ND, OH, OK, OR, PA, TN, TX, UT, VT, VA, WA, WV, WI, D.C.
States without Basic HCV Medications Coverage: MD, MT, RI, SC, SD
States with No Information on Basic HCV Medications Coverage: ID, MO, WY
Territories with Basic HCV Medications Coverage: Guam, P.R., U.S.V.I.
Sovaldi
States with Sovaldi Coverage: CA, CO, CT, FL, GA, HI, IN, KY, LA, MI, MS, MT, NE, NJ, NY, ND, OR, TN, TX, VA, WY, D.C.
States without Sovaldi Coverage: AL, AK, AZ, AR, DE, ID, IL, IA, KS, ME, MD, MA, MN, MO, NV, NH, NM, NC, OH, OK, PA, RI, SC, SD, UT, VT, WA, WV, WI
States with No Information on Sovaldi Coverage: None
Territories with Sovaldi Coverage: Guam, U.S.V.I.
Harvoni
States with Harvoni Coverage: CA, CO, CT, FL, GA, HI, IN, KY, LA, MI, MS, MT, NE, NJ, NY, ND, OR, TN, TX, VA, WY, D.C.
States without Harvoni Coverage: AL, AK, AZ, AR, DE, ID, IL, IA, KS, ME, MD, MA, MN, MO, NV, NH, NM, NC, OH, OK, PA, RI, SC, SD, UT, VT, WA, WV, WI
States with No Information on Harvoni Coverage: None
Territories with Harvoni Coverage: None/Unknown
Zepatier — Merck discontinued Zepatier effective December 1, 2025; this is the last edition in which the Watch tracks it (see the Zepatier entry in the Medicaid Formulary Notes).
States with Zepatier Coverage: AL, AR, CA, CT, FL, GA, KY, LA, MI, MS, MT, NE, NY, OR, TX, VA, WY, D.C.
States without Zepatier Coverage: AK, AZ, CO, DE, HI, ID, IL, IN, IA, KS, ME, MD, MA, MN, MO, NV, NH, NJ, NM, NC, ND, OH, OK, PA, RI, SC, SD, TN, UT, VT, WA, WV, WI
States with No Information on Zepatier Coverage: None
Territories with Zepatier Coverage: None/Unknown
Epclusa
States with Epclusa Coverage: CA, CO, CT, FL, GA, HI, IN, KY, LA, MI, MS, MT, NE, NJ, NY, ND, OR, TN, TX, VA, WY, D.C.
States without Epclusa Coverage: AL, AK, AZ, AR, DE, ID, IL, IA, KS, ME, MD, MA, MN, MO, NV, NH, NM, NC, OH, OK, PA, RI, SC, SD, UT, VT, WA, WV, WI
States with No Information on Epclusa Coverage: None
Territories with Epclusa Coverage: None/Unknown
Vosevi
States with Vosevi Coverage: CA, CT, FL, GA, HI, ID, IN, LA, MI, MS, MT, NE, NJ, NM, NY, ND, OR, TN, TX, VA, WY, D.C.
States without Vosevi Coverage: AL, AK, AZ, AR, CO, DE, IL, IA, KS, KY, ME, MD, MA, MN, MO, NV, NH, NC, OH, OK, PA, RI, SC, SD, UT, VT, WA, WV, WI
States with No Information on Vosevi Coverage: None
Territories with Vosevi Coverage: U.S.V.I.
Pegasys
States with Pegasys Coverage: AK, AZ, CA, CT, FL, GA, HI, IN, IA, KS, KY, LA, ME, MI, MN, MS, NE, NV, NH, NJ, NY, NC, ND, OH, OK, OR, TN, TX, UT, VT, VA, WA, WI, D.C.
States without Pegasys Coverage: AL, AR, DE, IL, MD, MA, MT, NM, PA, RI, SC, SD, WV
States with No Information on Pegasys Coverage: CO, ID, MO, WY
Territories with Pegasys Coverage: U.S.V.I.
Mavyret
States with Mavyret Coverage: AL, AK, AZ, AR, CA, CO, CT, DE, FL, GA, HI, ID, IL, IN, IA, KS, KY, LA, ME, MA, MI, MN, MS, MO, MT, NE, NV, NH, NJ, NM, NY, NC, ND, OH, OK, OR, PA, RI, SC, SD, TN, TX, UT, VT, VA, WA, WI, WY, D.C.
States without Mavyret Coverage: MD, WV
States with No Information on Mavyret Coverage: None
Territories with Mavyret Coverage: U.S.V.I.
Harvoni (generic)
States with Harvoni (generic) Coverage: AL, CA, CO, CT, FL, GA, HI, IN, KS, KY, LA, MI, MS, MT, NE, NH, NJ, NY, ND, OR, TN, TX, VA, D.C.
States without Harvoni (generic) Coverage: AK, AZ, AR, DE, ID, IL, IA, ME, MD, MA, MN, MO, NV, NM, NC, OH, OK, PA, RI, SC, SD, UT, VT, WA, WV, WI
States with No Information on Harvoni (generic) Coverage: WY
Territories with Harvoni (generic) Coverage: Guam, U.S.V.I.
Epclusa (generic)
States with Epclusa (generic) Coverage: AL, AK, AZ, AR, CA, CO, CT, DE, FL, GA, HI, IL, IN, IA, KS, KY, LA, ME, MA, MI, MS, MT, NE, NV, NH, NJ, NM, NY, NC, ND, OH, OK, OR, PA, SD, TN, TX, UT, VT, VA, WI, WY, D.C.
States without Epclusa (generic) Coverage: ID, MD, MN, MO, RI, SC, WA, WV
States with No Information on Epclusa (generic) Coverage: None
Territories with Epclusa (generic) Coverage: Guam, U.S.V.I.
State and Territory Medicaid Formulary Notes:
How the Watch scores non-preferred drugs. A state's general rule for non-preferred drugs governs hepatitis C drugs unless the hepatitis C section of the preferred drug list or criteria sets its own standard. Any rule that can be satisfied only by failing a preferred drug first is scored as no coverage, even where it allows exceptions for contraindication, intolerance, or side effects. A rule that also offers an open-ended route — medical necessity, clinical justification, a patient-specific reason, continuation for a patient already stable on the drug, or completion of a course already started — is not a barrier. A rule that allows only a contraindication or drug interaction, or only an indication no preferred drug shares, is a barrier, as are a "case-by-case" review standard and a medical-necessity determination made by the insurer rather than submitted by the prescriber. Prior-failure criteria that restate a drug's FDA labeling, as with Vosevi, are not a barrier. Where a score differs from July because this edition applies these standards in full, the underlying document is in most cases unchanged, and the difference does not reflect a change in state policy.
South Dakota's preferred drug list names only sofosbuvir/velpatasvir and Mavyret in its hepatitis C class and states: "If a medication is not listed within a PDL class, it is considered Non-Preferred for that class and may require additional steps for approval." It publishes a hepatitis C request form but no standard for approving a non-preferred drug, and the Watch scores the other hepatitis C drugs, including ribavirin and peginterferon, as no coverage.
Rhode Island covers only Mavyret as the Watch scores it. Its preferred drug list (updated 10/01/2026) places the non-preferred DAAs under a "Clinical PA Required + Trial of Preferred Agent" banner (page 26) and lists ribavirin and Pegasys as non-preferred with prior authorization (page 25). Non-preferred agents are reviewed "on a case-by-case basis" under the criteria (effective January 1, 2022), which the Watch scores as a barrier. This edition replaces the July edition's statement that Rhode Island's authorization pathway carries no treatment-failure requirement, and its coding of ribavirin and Pegasys as preferred without prior authorization.
Fibrosis testing. Twelve states and Puerto Rico condition at least some hepatitis C drugs on a fibrosis or cirrhosis assessment: Maryland, Massachusetts, Maine, Minnesota, Missouri, Oklahoma, Pennsylvania, South Carolina, Vermont, Washington, West Virginia and Wisconsin. In Maryland and West Virginia the requirement reaches every DAA (in Maryland, for every patient with chronic hepatitis C), and the Watch scores their DAAs as no coverage. Kentucky's simplified treatment pathway (criteria version October 2026) uses a FIB-4 score below 3.25 to confirm that a patient has no cirrhosis, but its standard pathway requires no fibrosis test, so Kentucky is not counted.
Maryland — clinical criteria (MDH, May 2026) consider coverage only when "all the criteria below are met," and the criteria for chronic hepatitis C include an "Accepted fibrosis test (ex. fibrosure, hepascore/fibroscore, liver-biopsy, fibroscan, ...)." The acute hepatitis C criteria include no fibrosis test, and the test is "Not required in the treatment of HCV-Uninfected Recipients of organs from HCV-Viremic Donors."
Montana — no longer counted. Its six drug-specific prior authorization forms (printed 04/2024) ask for a fibrosis stage without marking the field required, and the eight-week Mavyret box reads "Check if applicable ... Liver Fibrosis Stage F0, F1, F2, F3 or F4 (cirrhosis-compensated)," covering every compensated stage. The Watch scores Mavyret, the non-preferred DAAs and both authorized generics as covered. Ribavirin and Pegasys remain no coverage because the September 10, 2026 preferred drug list applies clinical criteria to the class and none is published. Each form also has the member attest, "If I fail to return to my provider, I will not be eligible for re-treatment"; the Watch reads this as an acknowledgment, not a denial criterion, and scores Vosevi as covered.
West Virginia — hepatitis C prior authorization criteria (effective 9/16/2025; the title line misprints "Casgevy"): "All requests must supply a fibrosis score and at least one detectable HCV viral level with genotype, both obtained within six months prior to the start of therapy." Ribavirin is preferred without prior authorization and is scored as covered.
Missouri — criteria revised July 9, 2026 require a "Documented fibrosis score" for every DAA except Mavyret, which needs no prior authorization.
Washington — policy 12.35.30.99 requires a fibrosis staging test for every non-preferred DAA; Mavyret, the only preferred DAA, needs no prior authorization.
South Carolina — criteria for non-preferred agents (revised 08/01/2026) require "Staging of liver disease (Metavir score)" among the lab results a prescriber must submit. Mavyret, preferred without prior authorization since August 1, 2026, is unaffected.
Massachusetts — MassHealth's Table 44 (last revised 02/2026) sets no staging requirement for treatment-naive members receiving Mavyret or generic Epclusa, and its pharmacy system "will usually pay" those claims without prior authorization for members with no prior hepatitis C claims and none suggesting decompensated cirrhosis; every other DAA criteria set requires "results of diagnostic tests assessing hepatic fibrosis." The Watch scores Mavyret and generic Epclusa as covered, so Massachusetts, which had no scored DAA coverage in July, now has two.
Vermont — the hepatitis C prior authorization form (last updated 09/2025) marks "Fibrosis score" as required for every request outside the simplified treatment pathway; non-preferred DAAs are scored as no coverage.
Oklahoma — the Hepatic Disorders prior authorization page (last modified October 14, 2026) requires a "Liver fibrosis assessment (METAVIR equivalent)" on the initial request for Harvoni and generic ledipasvir/sofosbuvir, Sovaldi, Vosevi, Zepatier and brand Epclusa.
Pennsylvania — the hepatitis C guidelines (effective January 5, 2026) require for non-preferred DAAs "a cirrhosis assessment documented by a recent noninvasive test (e.g., blood test or imaging, a Fibroscan, FIB-4 calculation, or findings on physical examination)." The Watch counts the required assessment as a fibrosis requirement, although a physical examination can satisfy it.
Wisconsin — ForwardHealth Topic #18297 requires medical records documenting "Liver biopsy, imaging studies, or blood assay tests to determine hepatic fibrosis" for non-preferred drugs.
Maine — MaineCare's hepatitis C prior authorization form (R: 10.25) asks the prescriber to attest that labs within the past six months include a "Fibrosis score" on every request.
Minnesota — the hepatitis C criteria sheet (January 2025) requires "Clinical documentation of patient's liver cirrhosis status" for non-preferred agents.
Puerto Rico — the Mavyret protocol (revised 9-2025) requires that the absence of cirrhosis or compensated cirrhosis be "evidenced by at least ONE of the following criteria, documentation with recent evidence must be attached," listing seven options from liver biopsy, FibroTest and FibroScan to imaging and clinical findings; the Epclusa protocol (Rev. 11/2024) has a similar requirement that does not list FibroScan. A 2023 circular letter (Carta Normativa 23-0728) eliminated the requirement to perform a FibroScan before treatment, but both protocols still require attached evidence.
Advanced cirrhosis. Epclusa and its authorized generic are labeled, with ribavirin, for decompensated cirrhosis in every genotype (Epclusa prescribing information, DailyMed, February 6, 2025), and Harvoni and its authorized generic in genotype 1 only (Harvoni prescribing information, DailyMed, January 13, 2025); Sovaldi is indicated only for patients "without cirrhosis or with compensated cirrhosis" (Sovaldi prescribing information, DailyMed, January 13, 2025), and Mavyret, Vosevi and Zepatier are contraindicated or not recommended in Child-Pugh class B or C. New Hampshire's Hepatitis C Criteria (approved May 12, 2026) and Oklahoma's Hepatic Disorders page limit only those four drugs in advanced cirrhosis, in line with their labels. An exclusion limited to decompensated cirrhosis does not change a coverage score; these notes state what patients with advanced cirrhosis cannot get. Minnesota and Wisconsin exclude such patients from drugs whose FDA labels permit treatment in that group; the Watch scores those drugs as no coverage in both states under their non-preferred standards, cited above, not because of the exclusions:
Minnesota — Minnesota Medicaid excludes 'Decompensated liver disease with CPT > 12 or MELD > 20' from approval of every non-preferred HCV agent (criteria sheet, January 2025), so patients in that group cannot get Epclusa, Harvoni or either authorized generic, the drugs labeled for decompensated cirrhosis (Harvoni and its generic in genotype 1 only). The remaining preferred agents are Mavyret (contraindicated in Child-Pugh B/C by label), Pegasys (contraindicated in decompensation) and ribavirin, so no direct-acting antiviral remains covered for them. Patients with decompensated cirrhosis at CPT 7-12 and MELD 20 or below can seek the non-preferred agents only under the non-preferred standard cited above, which the Watch scores as no coverage.
Wisconsin — Wisconsin Medicaid applies its Child-Pugh exclusions only to non-preferred drugs: CTP class C is excluded for every non-preferred agent, and class B also for Sovaldi, Vosevi and Zepatier (ForwardHealth Topic #18297). Members with decompensated cirrhosis can still get the preferred generic sofosbuvir/velpatasvir with ribavirin, with no prior authorization, but members in CTP class C cannot get brand Epclusa, Harvoni or generic ledipasvir/sofosbuvir, although Epclusa is labeled for decompensated cirrhosis and Harvoni for it in genotype 1. The class B and C limits on Sovaldi, Vosevi and Zepatier follow those drugs' labels.
Program changes this quarter.
South Carolina — the hepatitis C criteria (revised 08/01/2026) record "Removed Mavyret from criteria (no PA on Mavyret)," effective August 1, 2026. The P&T Committee (May 6, 2026) moved Epclusa, generic Epclusa and Vosevi to non-preferred, effective August 1, 2026, where a reason for using a non-preferred drug must now be documented. Mavyret was already preferred in July. The staging requirement applied to all three drugs in July and still applies, so they are scored as no coverage in both editions.
North Dakota — preferred drug list version 2026.7 (effective October 1, 2026) lists Mavyret and generic sofosbuvir/velpatasvir as preferred with no prior authorization ("Remove PA" in its "Prior Authorization Updates" table); brand Epclusa remains non-preferred with prior authorization. The hepatitis C section dropped the sobriety, treatment-program or attestation clause, the life-expectancy rule, the HCV RNA and fibrosis documentation rules for first-time treatment, adherence visits and the re-treatment specialist requirement; re-treatment with Vosevi still requires "1 positive HCV RNA test since most recent DAA treatment." The state's NDC Drug Lookup, queried October 28, 2026, shows oral ribavirin and Pegasys, which are not on the list, as covered with no prior authorization, and the Watch scores both as covered; the Pegasys score differs from July's because the Watch now reads this lookup, not because the program changed. Zepatier, absent from the list since Version 2026.1 (effective January 1, 2026), is scored as not covered although the lookup still shows it covered with prior authorization.
Oklahoma — the Hepatic Disorders prior authorization page (last modified October 14, 2026): "Mavyret and generic Epclusa (sofosbuvir/velpatasvir 400-100mg) are available with NO prior authorization and are the preferred direct acting antivirals (DAA)." The June 10, 2026 Drug Utilization Review Board packet (p. 311) named Mavyret alone as "SoonerCare's preferred direct acting antiviral."
North Carolina — the PDL Review Panel (July 9, 2026) "Moved Vosevi™ Tablet from preferred to non-preferred," effective October 1, 2026. The preferred drug list effective October 1, 2026 requires "Trial and failure (T/F) of two Preferred drugs ... unless only one Preferred option is listed or a T/F criteria exemption is otherwise indicated," and its subsection for patients who have already taken an NS5A inhibitor lists Vosevi alone. The PDL grants that subsection no exemption, and the hepatitis C class lists Mavyret and generic Epclusa as preferred, so the Watch applies the two-drug rule to Vosevi, as it does to North Carolina's other non-preferred hepatitis C drugs, and scores Vosevi as no coverage. Vosevi's own prior approval criteria (amended October 20, 2023) follow its FDA labeling and are not scored as a barrier.
Zepatier — Merck discontinued Zepatier effective December 1, 2025. Four programs removed it effective October 1, 2026: Colorado (non-preferred on the July 1, 2026 preferred drug list and absent from PDL 10-01-26 V3, effective October 13, 2026), Utah (listed through the September 1, 2026 preferred drug list and absent from the list effective October 1, 2026), and UnitedHealthcare's Hawaii QUEST and New Jersey FamilyCare plans (absent from the Hawaii QUEST and New Jersey preferred drug lists effective October 1, 2026). North Dakota's preferred drug list has omitted it since Version 2026.1 (effective January 1, 2026); the October 1, 2025 version listed it as non-preferred. The Watch scores Zepatier as not covered in all five.
Territories. Puerto Rico's Plan Vital lists Mavyret and generic Epclusa as preferred with prior authorization and ribavirin as preferred (PDL Salud Física, revised 10/2026); under the fibrosis rule it covers ribavirin only. The U.S. Virgin Islands lists nine of the ten tracked drugs, the broadest territorial formulary; it lists adult strengths of Harvoni and Epclusa only as authorized generics, under the header "Brand name drugs with generic substitutes available are not covered," and the Watch scores the brands as not covered. Every page of the governing document states "THIS DOCUMENT LIST IS EFFECTIVE through 3/31/2024," and nothing supersedes it. Guam's formulary (last updated July 2025) covers Sovaldi, both authorized generics and ribavirin, and no glecaprevir/pibrentasvir. American Samoa's only hospital, LBJ Tropical Medical Center, lists no hepatitis C treatment on its formulary (update 3/2022), but the list is incomplete, since its April 2026 price file bills HIV drugs not on it, and the American Samoa State Plan (updated as of 06/2026) excludes only investigational drugs, so the Watch records No Information for all ten drugs.
Territorial coverage is not directly comparable to a state's. Guam, American Samoa, the Northern Mariana Islands and the U.S. Virgin Islands are each waived out of the Medicaid Drug Rebate Program (for the U.S. Virgin Islands, CMS approval of July 11, 2023). The federal Medicaid match is set in statute at 83 percent, permanently, for those four territories, and at 76 percent for Puerto Rico through September 30, 2027 (HHS FY 2027 federal matching shares notice, November 28, 2025), and unlike the states, each territory's annual federal Medicaid funding remains capped under Section 1108 of the Social Security Act (KFF, updated September 8, 2025). This edition replaces the July edition's figure of a 55 percent federal match for the territories with these rates, per the HHS notice. Micronesia, the Marshall Islands, and Palau have no United States Medicaid program under Section 1101(a)(1) of the Social Security Act and are excluded from every denominator.
Mississippi — the Division of Medicaid's website has been offline since about October 14, 2026, citing "a temporary outage affecting our web-hosting vendor." Coverage reflects the state's MESA Pharmacy Drug Coverage Inquiry (effective date October 20, 2026), re-checked October 27, 2026 with no change, and the Hepatitis C prior authorization packet, Version 17 (effective July 28, 2026), which, like the October 2026 preferred drug list, could not be retrieved from the state that day.
The following states' Medicaid programs offer multiple coverage plans for their respective Medicaid clients. The plan highlighted in bold typeface represents the most comprehensive plan with the most drugs covered in the respective state:
Hawaii – (1.) AlohaCare; (2.) HMSA; (3.) Kaiser Permanente; (4.) 'Ohana Health Plan; (5.) UnitedHealthcare QUEST Integration
New Jersey – (1.) Aetna; (2.) Fidelis Care; (3.) Horizon NJ Health; (4.) UnitedHealthcare of New Jersey (New Jersey Family Care); (5.) Wellpoint (formerly Amerigroup NJ)
New Mexico has had a single preferred drug list for all Medicaid members, including every Turquoise Care plan, since July 1, 2026 (Medicaid PDL FAQ, 7/27/26)
Kentucky, Louisiana and Ohio each have a Unified Medicaid Formulary; Ohio's Unified Medicaid Formulary applies to all MCOs.
Indiana - Harvoni, Sovaldi and generic Harvoni are non-preferred and require "member specific justification for use over preferred agents," and brand Epclusa 400-100 mg requires justification over the authorized generic (criteria 12.01.2025), which the Watch does not score as a barrier. Mavyret and generic Epclusa are preferred, and Vosevi's criteria restate its FDA labeling. Zepatier is absent from every 2026 edition of the preferred drug list, which states that "Drugs that will be, or have been, withdrawn from the market will be removed from the SUPDL."
New Hampshire - Epclusa, Harvoni, Sovaldi, Vosevi, and Zepatier are non-preferred, requiring failure of preferred options before allowing use (preferred drug list effective November 1, 2026)
Continuing Policies:
No state Medicaid program's written criteria make sobriety a condition of initial treatment. Kentucky applies a sobriety period only at retreatment (see the Kentucky Vosevi entry above), and Alaska's prior authorization form asks whether the patient agrees to abstain from alcohol during treatment, which its criteria do not make a condition of approval. Six states require a substance-use assessment, counseling or attestation without requiring abstinence: Alaska (a prescriber's assessment of alcohol and substance misuse and a signed Patient Readiness Assessment Attestation (revised 10/03/2022)), Mississippi (documented counseling on abstinence from alcohol and IV drug use for patients outside its simplified pathway; see the Mississippi note above), Montana (a psychosocial readiness evaluation covering alcohol and substance use, per its prior authorization forms), Nebraska (counseling on the harms of alcohol and substance use on treatment, hepatitis C criteria, last revised 05/12/2026), Oklahoma (prescriber counseling on the harms of illicit IV drug and alcohol use, for drugs that require prior authorization) and Virginia (a prescriber evaluation for substance use disorder, including alcohol use disorder, hepatitis C service authorization form, revised 05/23/2019). North Dakota removed its sobriety, treatment-program or attestation clause effective October 1, 2026 (see the North Dakota note above).
4. VETERANS PROGRAMS & HCV THERAPIES
The Veterans Health Administration (VHA) lists every hepatitis C drug tracked in the Watch on the VA National Formulary (VANF) except Sovaldi and Zepatier, which prescribers can request through the non-formulary process. The current VANF is the September 2026 edition (printed "Sep-26"; U.S. Dept. of V.A., 2026a). Ribavirin (capsule and tablet) and peginterferon alfa-2a (Pegasys) are on the formulary without restriction. Ledipasvir/sofosbuvir (Harvoni and its generic), sofosbuvir/velpatasvir (Epclusa and its generic), sofosbuvir/velpatasvir/voxilaprevir (Vosevi), and glecaprevir/pibrentasvir (Mavyret) tablets are on the formulary with facility-level prior authorization (PA-F) and a national Criteria for Use, each "Updated June 2024." Because the VANF lists drugs by generic name and dosage form, one entry covers brand and generic tablets, and pediatric pellet forms are non-formulary. For Sovaldi and Zepatier, VHA Directive 1108.08 (July 29, 2022) states that non-formulary drugs "are only to be approved when one or more of the following applies": a documented contraindication, adverse reaction or inadequate response to the formulary alternatives; no formulary alternative; a patient already responding to the drug for whom a switch carries serious risk; or "other circumstances having compelling evidence-based clinical reasons."
The VA's clinical guidance, "Chronic Hepatitis C Virus (HCV) Infection: Treatment Considerations," was last updated March 18, 2021 (U.S. Dept. of V.A., 2021b), and the June 2024 Criteria for Use still refer prescribers to it. Its genotype-specific Tables 7, 11, 13 and 15 list the regimens below. The document states that within each category "regimens are listed in alphabetical order; this ordering does not imply any preference for a particular regimen unless otherwise indicated."
Abbreviations:
CTP – Child-Turcotte-Pugh (score used to assess severity of cirrhosis)
DAA – Direct-acting antiviral
GT – Genotype (GT1a and GT1b are genotype 1 subtypes)
Hgb – Hemoglobin
IU/mL – International Units Per Milliliter
NS5A – Non-structural protein 5A (the target of NS5A inhibitors)
PEG-IFN/IFN – Peginterferon/Interferon
PI – Protease inhibitor (NS3/4A PI: NS3/4A protease inhibitor)
RAS – Resistance-associated substitutions
RBV – Ribavirin
SOF – Sofosbuvir (Sovaldi)
SVR – Sustained virologic response
Genotype 1:
Treatment-naïve without or with cirrhosis (CTP A):
Pangenotypic regimens
Mavyret: 3 tablets orally daily with food for 8 weeks; may consider 12 weeks in patients with poor prognostic factors
Epclusa: 1 tablet orally daily for 12 weeks
Non-pangenotypic regimens:
Zepatier: 1 tablet orally daily for 12 weeks if GT1a without baseline NS5A RAS or GT1b
Harvoni: 1 tablet orally daily
If HCV-infected (without HIV), non-cirrhotic, and baseline HCV RNA <6 million IU/mL: 8 weeks
If cirrhotic, baseline HCV RNA ≥6 million IU/mL, HIV/HCV-co-infected, or African American: 12 weeks
Consider adding ribavirin in CTP A patients
Treatment-naïve with decompensated cirrhosis (CTP B or C):
Harvoni: 1 tablet orally daily + ribavirin (600 mg/day and increase by 200 mg/day every 2 weeks only as tolerated) for 12 weeks
Epclusa: 1 tablet orally daily + ribavirin (1,000 mg if <75 kg or 1,200 mg if ≥75 kg, orally daily in 2 divided doses with food) for 12 weeks; start at lower ribavirin doses as clinically indicated (e.g., baseline Hgb).
Treatment-experienced (NS5A- and SOF-naïve [e.g., failed PEG-IFN/RBV ± NS3/4A PI]) without or with cirrhosis (CTP A)
Pangenotypic regimens:
Mavyret: 3 tablets orally daily with food
If PEG-IFN/RBV-experienced: 8 weeks if non-cirrhotic or 12 weeks if cirrhotic
If NS3/4A PI + PEG-IFN/RBV-experienced: 12 weeks
Epclusa: 1 tablet orally daily for 12 weeks
Non-pangenotypic regimens
Zepatier: 1 tablet orally daily for 12 weeks if GT1b, or if failed PEG-IFN/RBV and GT1a without baseline NS5A RAS
Harvoni: 1 tablet orally daily for 12 weeks; add ribavirin if cirrhotic
Treatment-experienced (NS5A-naïve and SOF-experienced) without or with cirrhosis (CTP A)
Mavyret: 3 tablets orally daily with food
If PEG-IFN/RBV + Sovaldi-experienced: 8 weeks if non-cirrhotic or 12 weeks if cirrhotic
If Olysio + Sovaldi-experienced: 12 weeks
Epclusa: 1 tablet orally daily for 12 weeks if GT1b
Vosevi: 1 tablet orally daily with food for 12 weeks if GT1a
Treatment-experienced (prior NS5A-containing regimen) without or with cirrhosis (CTP A)
Mavyret: 3 tablets orally daily with food for 16 weeks if failed an NS5A inhibitor without NS3/4A PI (e.g., Harvoni)
Vosevi: 1 tablet orally daily with food for 12 weeks
Treatment-experienced with decompensated cirrhosis (CTP B or C)
Epclusa: 1 tablet orally daily + RBV; start at lower RBV doses as clinically indicated (e.g., baseline Hgb);
If NS5A-naïve: 12 weeks
If NS5A-experienced: 24 weeks; NOT FDA approved for 24 weeks
Genotype 2:
Treatment-naïve or treatment-experienced (PEG-IFN/IFN ± RBV or Sovaldi + RBV ± PEG-IFN) without or with cirrhosis (CTP A)
Mavyret: 3 tablets orally daily with food for 8 weeks; 12 weeks if CTP A and treatment-experienced or in patients with poor prognostic factors
Epclusa: 1 tablet orally daily for 12 weeks
Treatment-experienced (NS5A-experienced) without or with cirrhosis (CTP A)
Vosevi: 1 tablet orally daily with food for 12 weeks
Treatment-naïve or treatment-experienced patients with decompensated cirrhosis (CTP B or CTP C)
Epclusa: 1 tablet orally daily + ribavirin; start at lower ribavirin doses as clinically indicated (e.g., baseline Hgb)
If NS5A-naïve: 12 weeks
If NS5A-experienced: 24 weeks; NOT FDA approved for 24 weeks
Genotype 3:
Treatment-naïve without cirrhosis or with cirrhosis (CTP A)
Mavyret: 3 tablets orally daily with food for 8 weeks; may consider 12 weeks if cirrhotic or in patients with poor prognostic factors
Epclusa: 1 tablet orally daily for 12 weeks
If CTP A, test for NS5A RAS
Add ribavirin if Y93H RAS present
Treatment-experienced (PEG-IFN ± RBV or Sovaldi + RBV ± PEG-IFN) without or with cirrhosis (CTP A)
Mavyret: 3 tablets orally daily with food for 16 weeks
Treatment-experienced (NS5A-experienced) without or with cirrhosis (CTP A)
Vosevi: 1 tablet orally daily with food for 12 weeks
If CTP A, consider adding ribavirin (no supporting data)
Treatment-naïve or treatment-experienced with decompensated cirrhosis (CTP B or CTP C)
Epclusa: 1 tablet orally daily + ribavirin; start at lower ribavirin doses as clinically indicated (e.g., baseline Hgb)
If NS5A-naïve: 12 weeks
If NS5A-experienced: 24 weeks; NOT FDA approved for 24 weeks
Genotype 4:
Treatment-naïve without or with cirrhosis (CTP A)
Pangenotypic regimens
Mavyret: 3 tablets orally daily with food for 8 weeks; may consider 12 weeks in patients with poor prognostic factors
Epclusa: 1 tablet orally daily for 12 weeks
Non-pangenotypic regimens
Zepatier: 1 tablet orally daily for 12 weeks
Harvoni: 1 tablet orally daily for 12 weeks
Treatment-naïve with decompensated cirrhosis (CTP B or C)
Pangenotypic regimen
Epclusa: 1 tablet orally daily + RBV for 12 weeks; start at lower ribavirin doses as clinically indicated (e.g., baseline Hgb)
Non-pangenotypic regimen:
Harvoni: 1 tablet orally daily + ribavirin (600 mg/day and increase by 200 mg/day every 2 weeks only as tolerated) for 12 weeks
Treatment-experienced (Sovaldi-experienced and NS5A-naïve) without or with cirrhosis (CTP A)
Mavyret: 3 tablets orally daily with food for 8 weeks if NS3/4A PI-naïve without cirrhosis, and 12 weeks if NS3/4A PI-experienced or CTP A
Epclusa: 1 tablet orally daily + ribavirin for 12 weeks; start at lower ribavirin doses as clinically indicated (e.g., baseline Hgb)
Treatment-experienced (NS5A-experienced) without or with cirrhosis (CTP A)
Vosevi: 1 tablet orally daily with food for 12 weeks
Treatment-experienced with decompensated cirrhosis (CTP B or CTP C)
Epclusa: 1 tablet orally daily + ribavirin; start at lower ribavirin doses as clinically indicated (e.g., baseline Hgb)
If NS5A-naïve: 12 weeks
If NS5A-experienced: 24 weeks; NOT FDA approved for 24 weeks
October 2026 Notes:
Formulary activity: The VA National Formulary decisions newsletters for May 2025 through September 2026 contain no action on any hepatitis C antiviral, ribavirin, or peginterferon. The most recent hepatitis C change was the removal of sofosbuvir tablets, listed in the November 2024 decisions newsletter (Volume 3, Issue 10).
Coverage status:
Ribavirin and Pegasys: on the formulary, unrestricted; ribavirin capsules and tablets are also on the Urgent/Emergent formulary.
Harvoni and generic ledipasvir/sofosbuvir; Epclusa and generic sofosbuvir/velpatasvir; Vosevi; Mavyret tablets: on the formulary with PA-F and Criteria for Use (June 2024).
Sovaldi: not on the formulary; can be requested through the non-formulary process, subject to the approval conditions in VHA Directive 1108.08. No Criteria for Use exists.
Zepatier: not on the formulary; can be requested through the non-formulary process, subject to the approval conditions in VHA Directive 1108.08. Its Criteria for Use (June 2024) limits use to "Genotype (GT) 1 or 4, treatment naïve, with or without compensated cirrhosis."
Criteria for Use: Each direct-acting antiviral Criteria for Use requires that care be provided by or in consultation with a VA/VA Community Care Hepatitis C Specialist, completed hepatitis B screening, and documented adherence counseling, and excludes patients with "Limited life expectancy" or "Documented ongoing nonadherence to prescribed medications or medical treatment." None requires fibrosis staging, a period of sobriety, or trial and failure of a preferred drug. The Vosevi criteria limit it to patients previously treated with an NS5A inhibitor or with sofosbuvir, as its FDA label does, but also exclude patients whose earlier treatment failed with both an NS3/4A protease inhibitor and an NS5A inhibitor, such as Mavyret, a group the label includes. The Mavyret criteria exclude the same patients unless a later Vosevi regimen has also failed, so a veteran whose first Mavyret treatment failed has no listed route to either drug outside local-facility review of individual exceptions. The Mavyret, Vosevi, and Zepatier criteria exclude decompensated cirrhosis (Child-Pugh B/C), consistent with their labels. The Epclusa criteria cover decompensated cirrhosis in genotypes 1–6, and the Harvoni criteria cover it for treatment-naïve patients with genotype 1, 4, 5 or 6 and for genotype 1 patients previously treated with "pegylated interferon or NS3/4A inhibitor only," but not treatment-experienced patients without cirrhosis or with compensated cirrhosis, although Table 7 of the Treatment Considerations lists Harvoni for them.
Testing: An analysis of VHA data for 2021–2023 (Varley et al., Open Forum Infectious Diseases, May 16, 2025) found that 75% of the 6,637,294 people aged 18–79 in VHA care had received hepatitis C testing; of those, 5% were antibody positive, and 95.5% of antibody-positive patients received confirmatory testing.
Retreatment: The Treatment Considerations (March 18, 2021) state that "All patients with chronic HCV who do not have medical contraindications are potential candidates for antiviral treatment, including patients who become reinfected with HCV after achieving SVR," and that reinfection "should be managed similarly to treatment-naïve patients, preferably with a pangenotypic DAA."
5. PATIENT ASSISTANCE PROGRAMS
The drug manufacturers and various national nonprofit organizations offer a variety of patient assistance programs (PAPs) to assist patients in accessing treatments. They include:
Support Path (Gilead Sciences)
Status: ACTIVE
Financial Assistance
Provides co-pay assistance for Epclusa, Harvoni, Sovaldi, and Vosevi through the Gilead Support Path Co-pay Savings Program, and for the authorized generics of Epclusa (sofosbuvir/velpatasvir) and Harvoni (ledipasvir/sofosbuvir) through the separate Asegua Co-pay Coupon, with enrollment on the Asegua co-pay website; Sovaldi co-pay enrollment is by phone only.
Co-pay assistance covers, verbatim, "up to a maximum of 25% of the catalog price for three bottles in cost-sharing assistance, valid for 6 months from the time of first redemption with no monthly limit"
The co-pay programs are valid only for prescriptions reimbursed by commercial insurance. They exclude prescriptions eligible for reimbursement by "Medicare or a Medicare Part D plan, Medicaid, TRICARE, VA, DOD, Puerto Rico Government Health Insurance Plan, or any other state or federally funded healthcare benefit program." Per the program: "Uninsured and cash-paying patients are not eligible to use the Savings Program."
Where an insurer operates a co-pay accumulator, Gilead may reduce assistance "to a per claim maximum of $25." Where an insurer operates a co-pay maximizer, the current brand terms state that Gilead "may reduce or discontinue the cost-sharing assistance available under the program," with no separate maximizer limit beyond the 25% cap above, and the Asegua coupon terms allow Asegua to reduce or discontinue assistance after "providing assistance in an amount not to exceed $9,500 or current maximum limit." These limits apply only when Gilead or Asegua determines that the insurer uses such a program.
Patients without insurance may be eligible to receive their Gilead or Asegua medication free of charge through the Support Path Patient Assistance Program (PAP). Sovaldi is not offered through the PAP. No income threshold is published; the Support Path enrollment form (dated 03/26) asks for household income and authorizes Gilead "to obtain a personal credit report" to determine PAP eligibility.
Insurance Support
Researches and verifies benefits and in-network pharmacy coverage for the prescribed Gilead or Asegua medication, and the patient's cost-sharing responsibility
Provides prior authorization and appeals requirement information, and lets prescribers submit an electronic prior authorization to the payer through the iAssist portal
Contact: 1-855-7-MYPATH (1-855-769-7284), Monday–Friday 9:00 a.m.–8:00 p.m. ET; fax 1-855-298-8700. Asegua product lines: 1-877-404-3157 (sofosbuvir/velpatasvir), 1-888-479-0318 (ledipasvir/sofosbuvir)
Website: https://www.mysupportpath.com/
myAbbVie Assist (AbbVie)
Status: ACTIVE
Free Medication
Provides Mavyret at no cost. Per AbbVie: "Medicines provided through myAbbVie Assist are 100% free; no co-pays or shipping costs."
Eligibility, per AbbVie: "If you are uninsured, receiving coverage through Medicare, or your health insurance isn't enough to cover the cost of my medicine, you may be eligible to receive free medicine."
Income criteria, as published: household of 1, "$63,840 or less"; household of 2, "$86,560 or less"; household of 3, "$109,280 or less"; household of 4, "$132,000 or less"; "After 4, add $22,720 for each additional dependent family member." These figures equal 400% of the 2026 HHS poverty guidelines (Federal Register, January 15, 2026) for the 48 contiguous states and D.C.
Medicare Part D beneficiaries with income below 150% of the Federal Poverty Level must provide proof of denial from the Medicare Extra Help program.
Approved patients "will receive free medicine for up to one year. At the end of your enrollment, you can re-apply." Patients whose commercial plan requires them to apply ("commonly known as alternate funding programs") are not eligible.
Contact: 1-800-222-6885
Website: https://www.abbvie.com/patients/patient-support/patient-assistance.html
AbbVie Mavyret Co-Pay Savings Card
Status: ACTIVE
Financial Assistance
Per the card: "PAY AS LITTLE AS $5 PER MONTH." Commercial insurance coverage for Mavyret is required. No income test applies.
Maximum benefit, verbatim: "the maximum lifetime benefit that may be available solely for the patient's benefit under the co-pay assistance program is $12,000.00." AbbVie also states that "restrictions, including monthly maximums, may apply." The monthly maximum is not published.
Not available to patients receiving reimbursement under any federal, state, or government-funded insurance program, "for example, Medicare [including Part D], Medicare Advantage, Medigap, Medicaid, TRICARE, Department of Defense, or Veterans Affairs programs," or "where prohibited by law or by the patient's health insurance provider."
"Patients residing in or receiving treatment in certain states may not be eligible," which are not named. No expiration date is printed; the offer is subject to "change or termination without notice."
Contact: 1-877-628-9738
Website: https://www.mavyret.com/cost
NeedyMeds
Status: ACTIVE
NeedyMeds Drug Discount Card
A nonprofit-operated cash-price discount card, not a patient assistance program: "This is a drug discount program, not an insurance plan." It lowers the price paid at the pharmacy counter and provides no free medication or financial award.
Per NeedyMeds' Google Play listing (updated May 26, 2026): "Save up to 80% on prescription and over-the-counter medications (when prescribed) at over 65,000 pharmacies across the United States." The Apple App Store listing for the same app says "Accepted at over 35,000 pharmacies across the United States."
Per the same listing, the card is "free, open to everyone — regardless of income, age, residency, or insurance status."
Cannot be combined with government coverage. Per NeedyMeds, patients "who have Medicare, including Part D, Medicaid or any state or federal prescription insurance can only use this card if they choose not to use their government-sponsored drug plan for their purchase. The card is not valid in combination with those programs."
Card credentials: BIN 019520, PCN NMeds, GRP DRUGCARD. Patient inquiries 1-888-602-2978.
Program search: https://www.needymeds.org/search-programs
TotalAssist (Patient Advocate Foundation)
Status: CLOSED — both hepatitis C funds
Patient Advocate Foundation and the Patient Access Network (PAN) Foundation announced a merger on March 3, 2026 and launched TotalAssist on July 1, 2026. TotalAssist does not operate waitlists; patients sign up to be notified when a fund opens.
Hepatitis C (HepC) fund — CLOSED. $2,500 guaranteed award; $6,000 maximum award over 12 months from approval. Eligibility: hepatitis C diagnosis; any health insurance that covers the qualifying expenses (Medicare, Medicaid, TRICARE and commercial coverage all qualify; uninsured patients do not); income at or below 500% of the Federal Poverty Level adjusted for regional cost of living; legal resident receiving treatment in the U.S. or a U.S. territory; prescribed a medication on the approved list.
Covered medications: Epclusa, Harvoni, ledipasvir-sofosbuvir, Mavyret, Pegasys, ribavirin, sofosbuvir-velpatasvir, Sovaldi, Vosevi, Zepatier
Hepatitis C (HepC) Health Equity fund — CLOSED. Same criteria and award amounts, plus a home address in a ZIP code served by a Health Equity Fund.
Open adjacent fund: Virology testing health equity — OPEN, $185 guaranteed, $250 maximum, for "monitoring viral load in chronic disease (such as HIV, HCV, and HBV)" and for diagnostic testing or testing to "guide treatment decisions" (insurance required; income up to 500% FPL; qualifying ZIP code). TotalAssist's open HIV, AIDS, and prevention fund lists no hepatitis C medications.
Notification signup: https://totalassist.org/notify/
Contact: 866-512-3861, Monday–Friday 8:30 a.m.–5:30 p.m. ET
Website: https://totalassist.org/
HealthWell Foundation
Status: CLOSED
Co-pay assistance with a maximum award of $10,000
Assistance type, verbatim: "Prescription Drug Copay or Insurance premium (Medicare Part B only)."
The fund is "temporarily closed to new patients due to lack of sufficient funding." Existing grants remain active for the 12-month grant cycle or until exhausted.
Eligibility: being treated for hepatitis C; private insurance, Medicare, Medicaid or TRICARE covering the qualifying medication; income at or below "500% of the Federal Poverty Level (adjusted for household size and high cost of living areas)"; receiving treatment in the United States
Contact: (800) 675-8416
Website: https://www.healthwellfoundation.org/fund/hepatitis-c/
The Assistance Fund
Status: WAITLIST — accepting waitlist patients
Per the program: "TAF is currently accepting requests to join the enrollment waitlist for this program. Waitlists are administered on a calendar-year basis. At the end of each calendar year, waitlist applications expire. Patients still seeking assistance must join waitlists for the subsequent calendar year."
Contact (hepatitis C fund): (855) 730-5873
Website: https://tafcares.org/program-listing
Good Days
Status: OPEN — accepting applications
Assistance amount: $2,100
Eligibility Criteria, verbatim:
"Patient is required to have government-sponsored insurance coverage (ex. Medicare, Medicaid, Tricare, Federal Employee) which covers at least 50% of the cost of treatment."
"Patient income must be at or below 500% of the Federal Poverty Level (FPL.)"
"Patient must have valid Social Security number to apply for assistance and receive treatment in the United States."
"Patient must be diagnosed with a covered disease and program must be accepting enrollments."
"Patient must be seeking assistance for a prescribed medication that is FDA approved to treat the covered diagnosis."
Apply: https://mygooddays.org/apply
Website: https://mygooddays.org/diseases-covered/hepatitis-c/
October 2026 Notes:
Good Days now requires government insurance. Good Days' hepatitis C fund remains open at $2,100, but its eligibility criteria now require government-sponsored insurance, such as Medicare, Medicaid, Tricare or federal employee coverage, that covers at least 50% of the cost of treatment; the July criteria did not limit it to government plans. Commercially insured patients therefore no longer qualify, except federal employees. Good Days' $2,100 award equals the 2026 Medicare Part D out-of-pocket cap.
Charitable foundations are the main route for Medicare and Medicaid beneficiaries. Because of the federal Anti-Kickback Statute (HHS Office of Inspector General Special Advisory Bulletin, September 2014), manufacturer co-pay cards exclude patients in Medicare, Medicaid, TRICARE, the VA and other federal health care programs. Of the four foundations tracked, Good Days has the only open hepatitis C fund, The Assistance Fund is taking waitlist requests, and TotalAssist's two hepatitis C funds and HealthWell's fund are closed.
Monitoring costs. TotalAssist's Virology testing health equity fund ($250 maximum) now covers viral load monitoring for hepatitis C in qualifying ZIP codes. No program in this section pays for fibrosis staging tests. Link2Labs sells direct-access lab tests, with no doctor's order or insurance required, to "the Uninsured, Underinsured & Self-Pay Community," including a hepatitis C antibody test with reflex to quantitative HCV RNA for $85.00 (link2labs.com, viewed October 26, 2026; contact admin@link2labs.com).
Pegasys. The FDA lists the Pegasys shortage as resolved, with a duration of January 24, 2025 to August 27, 2026. The manufacturer, pharma&, states that its patient assistance program "may offer financial support to eligible patients in the U.S." (855-443-7028); no criteria are published.
HarborPath helps "the uninsured gain access to free medication" but lists only one hepatitis C medication, Zepatier 100-50mg tablet (HarborPath hepatitis C article, "Last updated on April 28, 2025"; "Drugs We Carry" article, updated August 4, 2026), which Merck discontinued effective December 1, 2025, so HarborPath is not a practical hepatitis C route and is not listed above.
6. HARM REDUCTION PROGRAMS
Harm reduction, as it relates to opioid and stimulant use and HCV, covers measures designed to prevent or monitor prescription opioid, heroin, methamphetamine and other stimulant misuse and, as an effect, to help prevent the spread of HCV and HIV. The Co-Infection Watch covers the following measures: Syringe Exchange, Expanded Naloxone Access, Safe Consumption Sites, Updated Paraphernalia Laws (allowing possession of substance testing strips), Good Samaritan Laws, and Required Prescriber Education.
October 2026 Updates:
Syringe Exchange
Syringe Services Programs (SSPs) provide people who inject drugs (or whose prescriptions require injection) with sterile syringes, with or without exchange of used ones. (N.b. – states listed indicate only that at least one SSP exists within the state, regardless of the legality of SSPs under state law.)
States with Syringe Exchange: AK, AZ, AR, CA, CO, CT, DE, FL, GA, HI, ID, IL, IN, IA, KY, LA, ME, MD, MA, MI, MN, MO, MT, NV, NH, NJ, NM, NY, NC, ND, OH, OK, OR, PA, RI, SC, TN, TX, UT, VT, VA, WA, WV, WI, D.C.
States without Syringe Exchange: AL, KS, MS, NE, SD, WY
Territories with Syringe Exchange: Puerto Rico
Territories without Syringe Exchange: Guam, U.S. Virgin Islands
Expanded Naloxone
Naloxone is a drug used to counteract the effects of opioid overdoses. Expanded Access refers to statutes, state standing orders or pharmacist protocols that allow pharmacies to dispense naloxone without an individual prescription.
States with Expanded Naloxone: AL, AK, AZ, AR, CA, CO, CT, DE, FL, GA, HI, ID, IL, IN, IA, KS, KY, LA, ME, MD, MA, MI, MN, MS, MO, MT, NE, NV, NH, NJ, NM, NY, NC, ND, OH, OK, OR, PA, RI, SC, SD, TN, TX, UT, VT, VA, WA, WV, WI, WY, D.C.
States without Expanded Naloxone: None
Territories with Expanded Naloxone: Puerto Rico, Guam
Territories without Expanded Naloxone: American Samoa, Northern Mariana Islands, U.S. Virgin Islands
Safe Consumption Sites
Safe Consumption Sites (SCSs), also called overdose prevention centers, allow people to use drugs under supervision and typically provide sterile supplies, wound care, overdose response, infectious disease screening, and linkage to care. This section tracks states where at least one safe consumption site operates, whether or not state law authorizes it.
States with Safe Consumption Sites: NY, RI
States without Safe Consumption Sites: AL, AK, AZ, AR, CA, CO, CT, DE, FL, GA, HI, ID, IL, IN, IA, KS, KY, LA, ME, MD, MA, MI, MN, MS, MO, MT, NE, NV, NH, NJ, NM, NC, ND, OH, OK, OR, PA, SC, SD, TN, TX, UT, VT, VA, WA, WV, WI, WY, D.C.
Territories with Safe Consumption Sites: None
Updated Paraphernalia Laws
State paraphernalia laws have long prohibited possession of drug-use materials, including harm reduction supplies such as fentanyl testing strips. A state is listed when possessing fentanyl test strips carries no paraphernalia penalty under its law for at least some people. Fewer states protect every form of drug-checking equipment for at least some people: 32 and the District of Columbia, by LAPPA's count (September 2025).
States with Updated Paraphernalia Laws: AL, AK, AZ, AR, CA, CO, CT, DE, FL, GA, HI, ID, IL, IN, KS, KY, LA, ME, MD, MA, MI, MN, MS, MO, MT, NE, NV, NH, NJ, NM, NY, NC, OH, OK, OR, PA, RI, SC, SD, TN, UT, VT, VA, WA, WV, WI, WY, D.C.
States without Updated Paraphernalia Laws: IA, ND, TX
Territories with Updated Paraphernalia Laws: American Samoa, Guam, Northern Mariana Islands, Puerto Rico
Territories without Updated Paraphernalia Laws: U.S. Virgin Islands
Good Samaritan Laws
Good Samaritan laws protect people who seek emergency help for a drug overdose from some drug-related legal consequences. Beginning with this edition, the Watch sorts them into three tiers. An expanded law protects both the person who calls for help and the person who overdosed from arrest, as well as from charges and prosecution, for possession of illegal or illicit substances and of drug paraphernalia; the Watch requires protection from arrest because the threat of arrest deters people from calling for help. A law qualifies when it expressly bars arrest (for example, Ohio Rev. Code § 2925.11(B)(2)(b)) or when it makes the protected possession not a crime and nothing in it preserves arrest for that conduct. Where simple possession of drug paraphernalia is not an offense under state law, protection for drug possession is enough. A limited law is an overdose Good Samaritan law that falls short of that standard: it bars only charges or prosecution, omits paraphernalia, protects only some of the people involved, or offers only an affirmative defense or a mitigating factor. A jurisdiction with no overdose Good Samaritan law is listed as having none. Good Samaritan laws may or may not protect people on parole or probation.
States with Expanded Good Samaritan Laws: CA, CO, CT, DE, FL, GA, HI, IL, ME, MD, MS, MO, MT, NE, NV, NJ, NM, OH, OR, TN, VT, VA
States with Limited Good Samaritan Laws: AL, AK, AZ, AR, ID, IN, IA, KS, KY, LA, MA, MI, MN, NH, NY, NC, ND, OK, PA, RI, SC, SD, TX, UT, WA, WV, WI, WY, D.C.
States with No Good Samaritan Law: None
Territories with Expanded Good Samaritan Laws: Puerto Rico
Territories with Limited Good Samaritan Laws: Northern Mariana Islands
Territories with No Good Samaritan Law: American Samoa, Guam, U.S. Virgin Islands
Prescriber Education Required
States that require, through legislation or regulatory or licensing bodies, that physicians who prescribe controlled substances complete training on safer controlled-substance, opioid and/or pain-management prescribing, in addition to or as part of their initial education.
States with Prescriber Education Required: AL, AK, AZ, AR, CA, CO, CT, DE, FL, GA, HI, IL, IA, KS, KY, LA, ME, MD, MA, MI, NE, NV, NH, NJ, NM, NY, NC, OK, OR, PA, RI, SC, TN, TX, UT, VT, WA, WV, WI, WY
States without Prescriber Education Required: ID, IN, MN, MS, MO, MT, ND, OH, SD, VA, D.C.
Territories with Prescriber Education Required: None
Territories without Prescriber Education Required: Guam, Northern Mariana Islands, Puerto Rico, U.S. Virgin Islands
Harm Reduction Program Notes:
On April 24, 2026, SAMHSA issued updated harm reduction funding guidance ("Dear Colleague" letter) stating that "No HHS funding" may be used to buy or distribute syringes or needles for injecting illicit drugs, safer-smoking supplies, sterile water, saline or ascorbic acid used to facilitate drug use, or substance test strips "intended for use by people using drugs," or to support overdose hotlines that keep a person company while the person uses drugs. The test-strip limit does not apply to law enforcement, emergency medical services, public health officials or health care professionals in their duties. Naloxone and nalmefene, wound care, FDA-approved home HIV, hepatitis B, and hepatitis C tests, sharps disposal, and linkage to HIV and HCV treatment remain fundable. Sen. Edward Markey and colleagues asked SAMHSA to reverse the guidance in a May 8, 2026 letter.
The Syringe Exchange lists count a state when the NASEN SSP directory lists at least one program there with syringe services (directory checked October 28, 2026). Idaho moves to the list on that basis: Latah Recovery Center in Moscow "partners with the North Idaho AIDS Coalition to provide a safe syringe exchange" (NASEN profile, updated October 23, 2026), although Idaho repealed its syringe exchange law effective July 1, 2024 (House Bill 617). Oklahoma stays on the list although its statutory protection for syringe services programs (63 O.S. § 2-1101, enacted by SB 511 of 2021) expired July 1, 2026 after HB 2012 was not heard on the Senate floor: No More Dead Friends in Cushing still lists syringe services (NASEN profile updated October 22, 2026). Alabama's only NASEN listing, Vista Medical of Alabama (profile updated October 19, 2026), does not include syringe services. LAPPA's June 2026 summary (page 6) shows the same 44 states with an operational SSP, and LAPPA's July 2026 fact sheet counts 45, including Alabama. The U.S. Virgin Islands moves to the list without an SSP this edition: the June 2026 summary finds no SSP law in the territory, notes that syringes are paraphernalia under V.I. Code tit. 19 § 593, and reports no active SSP there or in Guam, which was absent from both July 2026 lists and is also listed without one, and NASEN listed none in the Virgin Islands on October 20, 2026.
LAPPA's "Overdose Reversal Agent Access: Summary of State Laws" (January 2025, research current to December 2024) reports that "All 50 states, the District of Columbia, and Puerto Rico" meet the Expanded Naloxone definition. The FDA approved Narcan 4 mg nasal spray for over-the-counter sale on March 29, 2023, and RiVive 3 mg on July 28, 2023, so those products can be sold without a prescription in every state and territory. The state laws tracked here matter chiefly for prescription-only formulations, such as injectable and higher-dose products.
Figure 23 counts any state with an operating site, whether or not state law authorizes it, and its title no longer says "State Authorized." Rhode Island's center, operated by Project Weber/RENEW in Providence, remains the only state-regulated site in the country (operator release, January 12, 2026). The two other known U.S. sites, both in New York City and run by OnPoint NYC, operate "in close partnership with the City Health Department" without state authorization (OnPoint testimony, March 4, 2026); the state Safer Consumption Services Act (S7617/A4916) remained in the Senate Health Committee, last action January 7, 2026. The Rhode Island center held its ribbon-cutting on December 10, 2024 (Brown University, December 10, 2024) and began serving participants in January 2025; the July 2026 edition dated its opening to the ribbon-cutting, and this edition dates it to the start of services. Its operators told NBC 10 on October 22, 2026 that 130 people had overdosed there and been saved since it opened. Its authorization runs to March 1, 2028 under H 5171 Substitute A (enacted June 6, 2025), which extended the program's sunset by two years. Vermont authorized overdose prevention centers in statute (18 V.S.A. § 4256; Act 178 of 2024), but Burlington's center had not opened as of October 7, 2026 (WCAX).
North Carolina lists "testing equipment" in its paraphernalia statute (G.S. 90-113.21(a)(4)) but lets users and harm reduction organizations possess it (G.S. 90-113.22(d)). Vermont's paraphernalia law (18 V.S.A. §§ 4475–4476) penalizes only sales to minors, so possession of testing strips is not an offense. Effective September 30, 2026, Delaware exempts any object used "to analyze or test a controlled substance," including drug-testing strips, from its paraphernalia law (16 Del. C. § 4773(3)); LAPPA's September 2025 survey predates that change and lists Delaware among the states whose exemption depends on who holds the strips. North Dakota and Texas are listed without updated paraphernalia laws this edition. North Dakota's paraphernalia chapter defines drug paraphernalia to include testing equipment and prohibits using or possessing it to "test, analyze" a controlled substance (N.D.C.C. §§ 19-03.4-01(4) and 19-03.4-03(1)). Its syringe-program statute lists testing strips among program supplies, but its paraphernalia exemption covers only "syringes, needles, and supplies appropriately collected under this section" (N.D.C.C. § 23-01-44(1)(c) and (7); code PDFs dated June 30, 2025), which does not reach strips a program hands out or a person carries. The Network for Public Health Law's 50-state drug checking survey (August 2024) reads the clause the same way, and LAPPA's September 2025 summary lists North Dakota among the states with no exception. Texas, absent from both July 2026 paraphernalia lists, has not changed its law: Tex. Health & Safety Code § 481.002(17)(D) defines paraphernalia to include testing equipment used to analyze a controlled substance, and § 481.125 makes possessing it to "test, analyze" a Class C misdemeanor (statutes as in force October 20, 2026). House Bill 1644 (89th Legislature), which would have exempted fentanyl and xylazine test strips, passed the House but was last referred to the Senate Criminal Justice Committee on April 24, 2025 and died at adjournment on June 2, 2025; the legislature next meets in regular session in 2027.
The July 2026 definition counted laws that barred charges or prosecution and stated that the listed laws did not prohibit arrest; this edition's expanded tier also requires protection from arrest. Nine states on the July list bar charging or prosecuting the person who calls for help but do not bar that person's arrest, and they move to the limited tier: Arizona (A.R.S. § 13-3423), Idaho (Idaho Code § 37-2739C), Kentucky (KRS 218A.133), Louisiana (La. R.S. 14:403.10), Minnesota (Minn. Stat. § 604A.05), New York (N.Y. Penal Law § 220.78), North Dakota (N.D.C.C. § 19-03.1-23.4), Pennsylvania (35 P.S. § 780-113.7) and Rhode Island (R.I. Gen. Laws § 21-28.9-4). Louisiana bars arrest only for the person who overdosed, and Minnesota's protection for the caller does not cover paraphernalia. Kentucky's law also shields an officer who arrests on probable cause from criminal or civil liability for false arrest or false imprisonment. The District of Columbia and Washington, both absent from the July lists, are also listed as limited. D.C. Code § 7-403 provides that drug possession and paraphernalia offenses "shall not be considered crimes" for a person seeking help in an overdose, but subsection (e) shields an officer who arrests a person for those offenses on probable cause from prosecution and from civil liability for false arrest, so the law does not protect the caller from arrest. RCW 69.50.315 bars charging or prosecuting the caller or the person who overdosed for drug possession only and does not address arrest or paraphernalia.
Six states join the expanded tier. Colorado, Maine, Oregon, Vermont and Virginia bar arrest and prosecution for drug possession for both the person who calls for help and the person who overdosed: Colo. Rev. Stat. § 18-1-711, which also covers possession of drug paraphernalia; 17-A M.R.S. § 1111-B, which grants immunity "from arrest or prosecution for a violation of law" other than listed excluded crimes, none of them drug offenses; ORS 475.898; 18 V.S.A. § 4254; and Va. Code § 18.2-251.03, which also covers possession of controlled paraphernalia under § 54.1-3466. Simple possession of other paraphernalia is not an offense in Oregon, Vermont or Virginia: ORS 475.525 and Va. Code § 18.2-265.3 reach only sale and possession with intent to sell, and 18 V.S.A. § 4476 penalizes only sales to people under 18. In Ohio, Senate Bill 288 (134th General Assembly) added paraphernalia and drug-abuse-instrument offenses to the immunity in Ohio Rev. Code § 2925.11(B)(2), effective April 4, 2023, and the section bars arrest as well as charge and prosecution; the immunity requires screening and referral to treatment within 30 days and applies at most twice. California, Connecticut and Nebraska remain in the expanded tier because their laws make the protected possession not a crime and nothing in them preserves arrest for it: Cal. Health & Safety Code § 11376.5 ("it shall not be a crime"), C.G.S. §§ 21a-267(d) and 21a-279(d) ("shall not apply") and Neb. Rev. Stat. § 28-472 ("shall not be in violation"); California's protection covers personal-use amounts and reaches the caller only where the overdose is related to the caller's own possession. Indiana's law remains limited: its bar on taking a person into custody (Ind. Code § 16-42-27-2(g)–(h)) covers only a person who obtained and administered an overdose-reversal drug, not every caller or the person who overdosed.
The Drug Enforcement Administration's waiver of the in-person examination requirement for prescribing controlled substances by telemedicine runs through December 31, 2026 under the "Fourth Temporary Extension of COVID-19 Telemedicine Flexibilities for Prescription of Controlled Medications" (90 FR 61301, December 31, 2025); no further extension or special-registration final rule had been published as of October 27, 2026. Buprenorphine does not depend on that waiver: the final rule "Expansion of Buprenorphine Treatment via Telemedicine Encounter", effective December 31, 2025 under a delay notice of March 24, 2025, allows a practitioner to start buprenorphine for opioid use disorder by audio-only telemedicine and prescribe up to a six-month supply, which SAMHSA describes as making the earlier temporary flexibilities permanent. DEA's final rule implementing the SUPPORT Act provisions on dispensing and administering controlled substances for medication-assisted treatment (91 FR 34754, June 9, 2026) took effect July 9, 2026.
Territorial Status:
Puerto Rico has allowed naloxone without a prescription since March 19, 2019 (LAPPA, January 2025). Guam, added this edition, is listed with expanded naloxone because LAPPA (page 8) places it with the District of Columbia among jurisdictions using prescriber-pharmacist standing orders. LAPPA finds no naloxone-access law in American Samoa, the Northern Mariana Islands or the U.S. Virgin Islands.
LAPPA (September 2025) finds that American Samoa, Guam and the Northern Mariana Islands appear to have no drug paraphernalia statute, so testing strips carry no paraphernalia penalty there, though LAPPA notes that its access to these territories' laws is limited. Puerto Rico defines testing equipment as paraphernalia but exempts its Department of Health, the prevention programs it authorizes and their identified participants, so the exemption depends on who holds the strips. The U.S. Virgin Islands defines testing equipment as paraphernalia with no exception.
Puerto Rico's opioid overdose prevention law bars the arrest, charging, prosecution or conviction of the person who overdoses and of the person who seeks help, for drug possession and for paraphernalia used to inject, ingest or inhale drugs, but not for testing equipment (Ley 35-2021, Art. 4, 24 L.P.R.A. § 2644, enacted August 27, 2021), and Puerto Rico is listed with an expanded Good Samaritan law; LAPPA's July 2025 summary does not include this law. The Northern Mariana Islands' law, listed as limited, provides only an affirmative defense to a possession charge, and American Samoa, Guam and the U.S. Virgin Islands have no Good Samaritan overdose law (LAPPA, July 2025).
FSMB (August 2026) lists no controlled-substance or pain-management education requirement for Guam, the Northern Mariana Islands, Puerto Rico or the U.S. Virgin Islands.
7. LATEST NEWS
Two ADAPs Report Waiting Lists as Twelve Project Deficits - NASTAD's ADAP Watch reports active waiting lists in Iowa (1,020 people, down from 1,035 in July) and Utah (84, up from 48). Iowa's waiting list followed the state's March 6, 2026 lawsuit alleging that its contract pharmacy, NuCara Specialty Pharmacy, failed to remit more than $22 million in 340B program income generated through the ADAP; the state opened the waiting list three days later. As CANN has documented, the shortfall was entirely preventable and reflects the gaps in 340B contract pharmacy oversight that the Government Accountability Office has found HRSA has largely left unaddressed. Twelve ADAPs project budget deficits, six of them major: Georgia, Hawaii, Iowa, Missouri, Pennsylvania and Texas. Iowa, Michigan, Missouri, Pennsylvania and the District of Columbia have reduced formularies in place, Missouri having "removed all non-antiretroviral medications from the formulary, effective June 1, 2026," and Georgia's ADAP full-pay medication program income limit drops to 200% of the federal poverty level effective November 1, 2026.
California Will Bar Prior Authorization for Hepatitis C Cures in State-Regulated Commercial Plans in 2027 - Assembly Bill 1843 (Asm. Sade Elhawary), passed by the Legislature on August 30, 2026, was chaptered on September 27, 2026 (Chapter 552, Statutes of 2026). New Health and Safety Code section 1342.78 bars health care service plans from subjecting medically necessary hepatitis C direct-acting antivirals to prior authorization, and new Insurance Code section 10123.1938 applies the same rule to health insurers; plans and insurers may still require prior authorization for therapeutically equivalent versions if at least one pangenotypic version is covered without it. The law does not apply to Medi-Cal managed care contracts or amend Medi-Cal fee-for-service rules. As a statute without an urgency clause, it takes effect January 1, 2027.
Georgia Adds HIV Diagnoses to Medicaid "Medically Frail" Lists - On August 13, 2026, Georgia's Board of Community Health gave final adoption to the State Plan Amendment establishing Medicaid community engagement requirements, which take effect January 1, 2027 upon CMS approval. Medical Frailty List Attachment A, conditions that satisfy medical frailty, lists "HIV disease resulting in malignant neoplasms" under code B21, which is not a code in the ICD-10-CM code set used for U.S. claims, where symptomatic HIV disease is B20. Medical Frailty List Attachment B, conditions that may qualify in combination with others, lists HIV disease (B20), "HIV, type 2" and asymptomatic HIV infection status (Z21). Chronic viral hepatitis C (B18.2) is on neither list, although both lists include cirrhosis and other complications of advanced liver disease. The proposal reported in July had omitted HIV. The board also approved public notice of an amendment to Georgia's Pathways to Coverage section 1115 demonstration seeking a 90% federal match for the Pathways population, effective January 1, 2027; Georgia submitted it on October 1, 2026, and CMS is accepting comments through November 8, 2026. A federal court's October 29 ruling on the federal definition of medical frailty is summarized below.
Court Strikes Narrower "Medically Frail" Test From Medicaid Work Requirement Rule - In Commonwealth of Massachusetts et al. v. Oz (D. Mass. No. 1:26-cv-12962), Judge Richard G. Stearns on October 29, 2026 vacated the part of CMS's June 2026 interim final rule requiring that a person's "physical, mental, or other behavioral health condition significantly impairs the individual's ability to comply with the community engagement requirement" in addition to falling within one of the five categories of medical frailty listed in H.R. 1, finding that requirement contrary to law, and enjoined CMS from applying it to the plaintiff states. The court upheld the rule's 12-month lookback on claims data and its limit of one self-attestation per enrollment period. Its order also bars CMS, for six months, from penalizing the plaintiffs, more than two dozen states and the District of Columbia, for errors or delays in implementing the rule. The ruling does not change the January 1, 2027 start date set by Congress. Section 71119 of H.R. 1 ends every good-faith exemption by December 31, 2028.
Federal Medicaid and CHIP Eligibility Ends for Many Lawfully Present Immigrants - Section 71109 of the 2025 reconciliation law (H.R. 1, P.L. 119-21) took effect October 1, 2026, ending federal Medicaid and CHIP eligibility for many lawfully present immigrants, including refugees and asylees without green cards; lawful permanent residents, Cuban and Haitian entrants, and Compact of Free Association migrants remain eligible, as do lawfully residing children and pregnant people in states that elect that option. KFF reports a Congressional Budget Office estimate of $6.2 billion in reduced federal spending and about 100,000 more uninsured people by 2034. States must submit updated State Plan Amendments by December 31, 2026.
HRSA Revives the 340B Rebate Pilot; Hospitals Sue - HRSA's revised 340B Rebate Model Pilot notice of August 3, 2026 lets manufacturers provide 340B ceiling-price savings as after-the-fact rebates instead of upfront discounts beginning January 1, 2027, limited to drugs with Medicare negotiated prices for 2026 and 2027. HRSA's pilot page lists approved plans from ten manufacturers, which Ryan White Clinics for 340B Access reports cover 18 of 20 eligible drugs. No HIV or hepatitis C drug is eligible, because none is on CMS's negotiation lists for 2026 or 2027; Gilead's HIV treatment Biktarvy is on the 2028 list, which the pilot does not cover. On October 9, the American Hospital Association, the Maine Hospital Association, and four hospitals sued in the District of Maine to block the pilot, and Reps. Bresnahan, Dingell, Mann, and Frankel introduced H.R. 10770, the 340B Rebate Model Delay Act, which its sponsors say would stop the rebate model "through 2028"; it has 16 cosponsors and remains in the Energy and Commerce Committee.
CDC Releases Viral Hepatitis 2030 Strategic Plan - CDC's Division of Viral Hepatitis released a 2030 Strategic Plan dated July 31, 2026. Its hepatitis C goals for 2030, measured on 2028 data, are 4,400 or fewer estimated new infections (a 90% reduction from 44,700 in 2017), hepatitis C-related deaths of 1.44 or fewer per 100,000 (a 65% reduction from 4.13 in 2017), and viral clearance of 80% or more for 2025–2028, up from 43% in 2013–2016. The plan cites "same-encounter hepatitis C test-and-treat models of care" and includes no funding amounts.
Cure Hepatitis C Act Adds Cosponsors - H.R. 9682, introduced July 14, 2026, has added three House cosponsors since the July edition, for six in total, and remains in four House committees with no hearing or markup. The related Senate bill, S. 1941, introduced by Sen. Bill Cassidy on June 4, 2025, has one cosponsor and no action since referral.
Overdose Deaths Continue to Decline - CDC provisional data predict 66,478 drug overdose deaths in the 12 months ending May 2026, down from 75,094 in the 12 months ending May 2025, an 11.5% decline. On September 25, 2026, SAMHSA announced $247.9 million in grants for addiction treatment, overdose-reversal training, school mental health, trauma treatment, and recovery support.
Helen Branswell, STAT News Stalwart Dies - Maintaining high-quality, fact-based, science-forward sources of data and reporting is essential. Helen Branswell, a well-known and widely respected infectious disease reporter, died at age 69 on October 13, 2026, due to complications from Cancer. Her work earned her many awards, including the Victor Cohn Prize for Excellence in Medical Science Reporting and the George Polk Award for Public Service. She was even a finalist for a Pulitzer Prize in 2021. She was particularly lauded for her insightful and evidence-based coverage of COVID. Her writing was bolstered by data-informed critical thinking instead of alarmist talking points. Public health officials who were the subject of some of her criticism held Branswell in the highest regard. After many years working through the ranks of the Canadian Press, she joined STAT News at its inception, adding to the publication’s reputation for trustworthy reporting.
9. CONTACT
Jen Laws, President & CEO
10. REFERENCES
Available upon request.
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