The EACH/PIC Coalition submitted a group letter signed by 22 organizations to the Maryland PDAD in response to proposed regulations defining the circumstances under which use of a drug may create an affordability challenge in the state.
The letter stated:
“As the board undertakes this effort, we encourage it to ensure that affordability determinations remain focused on patient affordability. While healthcare spending is an important consideration for policymakers, spending metrics alone do not demonstrate that patients are experiencing affordability challenges. Affordability reviews should therefore be grounded primarily in evidence that patients are struggling to afford treatment.”
“The purpose of an affordability review should be to identify and address affordability challenges experienced by patients. A finding that spending is high does not demonstrate that patients are struggling to afford a medication.”
“[W]e encourage the board to require that at least one patient affordability criterion be satisfied before a drug may advance to consideration of a UPL or other affordability intervention. If a policy is being pursued in the name of improving affordability, there should first be evidence that patients are experiencing affordability challenges associated with that drug.”
“Establishing this safeguard would help ensure that affordability reviews remain focused on improving patient affordability rather than solely reducing healthcare system spending.”