The EACH/PIC Coalition submitted comments to the Colorado PDAB in advance of their fourth rulemaking hearing to implement an upper payment limit for Enbrel. The letter urges the board not to proceed with a UPL and emphasizes the need for patient protections prior to implementation.
The letter stated:
“We remain concerned with the implications of setting an upper payment limit (UPL) for Enbrel in Colorado at the Medicare Maximum Fair Price (MFP). We offer the below input and urge the board not to proceed with establishing a UPL for Enbrel due to the potential unintended consequences for patients.”
“[A] UPL does not address the real problems patients identify. Instead of layering a new and untested pricing mechanism onto a system already stacked against patients, the board should focus on reforms that tackle these systemic drivers of unaffordability directly.”
“We remain deeply concerned that the board is considering moving forward with a UPL before establishing any safeguards or even a framework for monitoring and accountability. Monitoring the effects of a UPL after implementation is still “flying the plane while building it,” which cannot be a substitute for proactive protections. Patients will bear the immediate consequences of insurer and PBM responses, while any corrective action from the board could take months or years.”
“The board has heard, but so far failed to heed, repeated warnings from patients, patient organizations, hospitals, pharmacies, and providers of potential unintended consequences of implementing a UPL in Colorado. Patients must not bear the burden of policies that are untested, inadequately monitored, and unlikely to address the affordability barriers they actually face.”