Unhealthy substance use and physical inactivity are prevalent co-occurring risk factors for morbidity and mortality among people with HIV (PWH). Physical activity improves substance use, HIV, and other health outcomes, yet it is inconsistently addressed in routine HIV clinical settings. Following a pragmatic approach, we are eliciting perspectives on barriers and facilitators to promoting physical activity among PWH and unhealthy substance use in HIV clinical settings. To date, we have conducted three focus groups with HIV clinicians and clinic staff (n=12) and six individual interviews with PWH reporting unhealthy substance use from a large urban Ryan White funded Infectious Disease Clinic in New Haven, CT. Data collection and analysis are guided by the Health Equity Implementation Framework, with a focus on 1) innovation (physical activity program), 2) clinical encounter (between PWH and providers), 3) recipients (PWH with unhealthy substance use), and 4) context (Ryan White funded HIV clinic). Emerging themes identified barriers and facilitators at each level. Regarding innovation: barriers included a lack of evidence-based interventions tailored to this population and prolonged engagement in physical activity; facilitators included contingency management and app-based programs to educate and track behaviors. Regarding clinical encounter: barriers included physical inactivity not being routinely addressed, providers being unaware of the physical activity guidelines for PWH, and competing priorities; facilitators included establishing rapport and printed visual hand outs. Regarding recipients: barriers included lack of physical activity knowledge and awareness, cost of gym memberships, physical capacity restrictions, and substance use; facilitators included social support and tailoring physical activity services to individual interests/fitness levels. Regarding context: barriers included budget restrictions, physical activity not being considered as a Ryan White-eligible service, and lack of billing options for prescribing physical activity; facilitators included clinic buy-in, having an on-site physical activity specialist, and infrastructure to link patients to physical activity services. This ongoing research highlights the need for multilevel approaches to promote physical activity among PWH with unhealthy substance use. An interdisciplinary approach to bridge perspectives across multiple disciplines may improve implementation efforts.