The Affordable Care Act (ACA) requires non-grandfathered plans to cover certain preventive items and services at a $0 cost share to their members. For 2025, new additions include HIV pre-exposure prophylaxis (PrEP) based on recommendations from the US Preventative Services Task Force (USPSTF). Currently, Truvada and its generic tenofovir disoproxil fumarate and emtricitabine are considered preventative (for PrEP).
Recently, the USPSTF recommended two more medications for prevention, Descovy and Apretude. There are no generics currently available for these two medications, and as of January 1, 2025, most carriers have included these products in their ACA coverage when specified for approved use in PrEP. Note that Aetna has made the decision not to make any changes to their ACA list at this time.
PrEP Medication Overview
The table below shows the three formulations currently approved for PrEP and another formulation anticipated to launch later in 2025.
PrEP Medications:
| Drug | Maintenance Dosage | Dosage Form | Generic Available? |
| Truvada | Once Daily | Oral | Yes |
| Descovy | Once Daily | Oral | No |
| Apretude | Once every two months | Injection | No |
| Pipeline: Lenacapavir Anticipated launch 2025 |
Once every six months | Injection | N/A |
ACA Contraceptive Coverage Updates
There are frequent proposals to change components of the ACA's required preventive coverage. As stated above, the ACA mandates that non-grandfathered group health plans and health insurance issuers provide certain women’s preventive health services without cost-sharing, including FDA-approved contraceptive services and products deemed medically appropriate by a woman's healthcare provider.
During Trump's first administration, employers could be exempted based on religious beliefs or moral convictions. In 2023, the Biden administration proposed removing the moral exemption rule to expand access to contraception, making it harder for employer-sponsored health plans and insurers to exclude birth control coverage. However, as of late December 2024, the Biden administration withdrew these regulations, allowing employers to opt out of providing contraceptive coverage based on moral convictions, thus maintaining the previous rules.
Given the regular changes to the ACA, employers may have questions about their coverage requirements and related costs. It is recommended to consult with a dedicated Rx Solutions consultant for any questions regarding ACA coverage or obtain an updated list from their PBM.
Sources:
- CVS Health News Release. "ACA Preventive Services Program Update: HIV PrEP Coverage," CVS Health, 2024.
- Express Scripts Clinical Update. "Affordable Care Act Preventive Services: HIV PrEP Coverage Update," Express Scripts, 2024.
- Noah Tong. "Feds Rescind Proposed Rule Requiring Contraception Access," Fierce Healthcare, 2024.
- Alice Miranda Ollstein. "Biden Administration Scraps Rules to Expand Birth Control Access," Politico, 2024.
- Nathaniel Weixel. "Biden Administration Withdraws Birth Control Rules," The Hill, 2024.
