The EACH Coalition submitted a comment letter on the proposed rules and policies the Maryland PDAB proposed to govern its upper payment limit implementation process. The Coalition was joined by 29 organizations that comprise its national network.
The letter urged the board to create a more formalized process for patient input, integrate input from patient organizations, consider alternatives to UPLs, and proactively protect patients from utilization management.
The letter stated:
“We urge the board to put significant emphasis on gathering input from patients during the information gathering process of establishing a UPL. This will ensure that the board is appropriately identifying and addressing real patient problems and that patients’ lived experiences are addressed by board proposed policy solutions. … Further, we recommend that the board work directly with patient organizations to better understand and attain patient perspectives.”
“The board currently has no authority to implement alternative policies nor has it outlined any alternatives under consideration. Proceeding with the UPL process without taking these important steps increases the likelihood that the board will resort to implementing UPLs simply because other policy solutions have not been explored and are therefore not available to implement.”
“While UPLs are intended to lower costs for patients, the reality is that they will create a new incentive structure for payers that could compromise patient access to the selected medications due to increased utilization management or reshuffling of formularies. We appreciate the board’s recognition that this could be a consequence of UPL implementation; however, we are disappointed that the board only intends to monitor for these changes after the UPL has been implemented.”