The EACH/PIC Coalition submitted comment letters to the Maryland PDAB, providing input and feedback on the drug reviews for Ozempic and Trulicity and the proposed UPL framework for Jardiance and Farxiga.
The letter stated:
“As the board begins its discussion of the proposed UPL frameworks for Jardiance and Farxiga, we encourage greater transparency regarding the supplemental rebate component referenced in prior discussions. Although stakeholders were advised that details would be included in the UPL Action Plan, that document does not currently describe how these rebates would operate or what their intended purpose may be. We respectfully ask the board to clarify how such rebates would be designed, administered, and evaluated.”
“We also underscore the limitations of a UPL in addressing patient affordability. UPLs may change what insurers or the state pay for a medication, but they do not cap or guarantee reductions in patient out-of-pocket costs. As our coalition has cautioned before, these policies can introduce new incentives for insurers and pharmacy benefit managers (PBMs) that may ultimately restrict access to needed treatments through greater utilization management, formulary reshuffling, or adverse tiering.”
“While intended to reduce costs, implementing a UPL without complementary patient protections could worsen the very challenges patients already face. We therefore urge the board to establish clear safeguards before advancing any UPL frameworks and to continue exploring its policy alternatives—including reforms that directly address PBM and insurance practices that most influence patient costs.”