Ryan White HIV/AIDS Program Part A and B Formula Alterations Comments

December 10, 2025

VIA ELECTRONIC SUBMISSION

Division of Policy & Data

HIV/AIDS Bureau

Health Resources & Services Administration

5600 Fishers Lane

Rockville, MD 20857

Re: Public Notice Improving Ryan White HIV/AIDS Program Part A and B Formula Awards Using Most Recent Address Data (FR Doc 2025-19838)

Dear Mr. Mandsager:

HealthHIV supports the proposed update to the Ryan White Part A and B formula calculations, with important implementation considerations.

We believe that using the most recent address is the more accurate metric. From an implementation standpoint, improved surveillance accuracy supports data-to-care work and also strengthens data-to-action activities by giving jurisdictions a clearer picture of where needs are emerging. At the same time, support for this update must be paired with a clear understanding of the operational risks it creates for the continuity of care.  

The risk to continuity will be felt most in jurisdictions where funding shifts down. This is especially true in jurisdictions where many long-term and lifetime survivors began treatment prior to the widespread use of single-tablet regimens (2006), as well as those treated during periods when care was far more demanding and harder on the body, and who now have higher needs. It is also true for people who want to age in place but face rising healthcare costs across the board.

To that point, most PWH are now over 50. Many live with multiple chronic conditions and rely on stable, long-standing relationships with HIV providers, pharmacists, and community and supportive programs. The risk comes from what happens after the data changes the maps. When case counts shift, funding shifts. And when funding shifts, capacity shifts. That determines where workforce, case management, and supportive services can and do function.

Because HIV care (and its communicability without care) does not stop at jurisdictional borders, funding shifts do not reduce the need across communities where the epidemic and populations continue to age in place. This includes Part B rural and suburban areas already faced with long-standing service gaps, even as many PWH still travel into nearby Part A cities for care—in jurisdictions where funding in some EMAs, TGAs, and states may have also shrunk. Our Ryan White care system (alongside more recent data showing that efforts and outcomes better align when syndemic needs are addressed) has been built over 30 years and cannot scale down—or scale up—overnight, meaning rapid redistribution creates instability on both sides of the formula. If we reduce this to using data as a way to label jurisdictions as “winners vs. losers,” we shift a needed technical (but critical) update into a fight about geography—instead of a public health discussion about allocations, continuity, mobility, and workforce drain and strain.

So our message is: The epidemic moves, but the care system cannot move at the same speed. Funding reductions alone do not reduce the intensity of need for people who remain. HRSA must modernize the formula while protecting care continuity in jurisdictions that still carry high-acuity populations. This NPRM focuses on data alignment; it does not yet address the operational consequences of that alignment.

To maintain stability across the HIV care system, we respectfully recommend:

• A transition paired with operational guardrails to prevent care disruptions for older adults, long-term survivors, rural patients, and jurisdictions with limited HIV workforce capacity.

• HAB should work with technical assistance providers, recipients, and subrecipients to keep comprehensive services available in all areas with PWH, regardless of funding shifts. TA should move beyond fiscal modeling to strengthen issues around care coordination, HIV and comorbidity pharmacy access, mental and behavioral health supports, food and dental services, housing (and support to stay housed), and transportation—especially in jurisdictions with aging populations and long-standing fragmentation.

Many of the jurisdictions facing reductions serve aging populations whose care needs increase over time; reduced allocations do not translate into reduced service intensity. And while many people were diagnosed in cities they left decades ago, the jurisdictions that lose funding still care for older adults who remained, whose needs have grown more complex. Correcting the geography does not diminish those ongoing responsibilities. Because not all states or EMAs/TSAs have strong Part A–Part B integration, we further encourage HRSA HAB to support cross-jurisdiction planning and shared resource strategies so that formula changes do not widen gaps in service capacity.

• With HHS integrating NIH and CMS data through a new AI platform, HRSA should clarify how these changes may affect Ryan White data interpretation, allocation modeling, and program integrity assessments, including how integrated datasets will be used to support—not replace—local planning and coordination with lead jurisdictions.

• Regular transparency on CDC’s most-recent-address methodology—including frequency of updates and validation processes—so jurisdictions can plan realistically for annual shifts in case distribution.

• Focused analysis of the transition’s impact on the HIV workforce, including providers who serve high-acuity, high-needs (met or unmet) patients. This area has been under-examined and is essential to ensure care continuity.

• A plan to stabilize services in jurisdictions with declining allocations, particularly those serving older PWH, long-term and lifetime survivors, or areas with persistent health stability needs.

In short, the goal of modernizing data should be to strengthen—not destabilize—the care system. Aligning funding with where people live is a necessary update, but it must be paired with scaled supportive services that reflect the real-world pressures facing HIV providers, ADAPs, case managers, and community programs, alike.

HealthHIV appreciates the opportunity to comment and encourages HRSA to implement this methodological change in a way that best, most protects service continuity; responds to the needs of older adults with HIV; and supports the workforce that anchors our Ryan White system.

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