The EACH/PIC Coalition submitted a comment letter to the Maryland PDAB, providing input on the board’s ongoing drug reviews.
The letter stated:
“We appreciate the opportunity to submit comments as the board continues its affordability review process and considers policy pathways. We share the board’s goal of improving affordability for Maryland patients; however, we remain concerned that UPL-focused approaches are unlikely to resolve the challenges patients actually face and may introduce new risks to access. We respectfully urge the board to prioritize non-UPL policy options that more directly address patient-reported barriers to affordability and access.”
“Our latest research, the Patient Experience Project: Patient-Reported Affordability & Unaffordability Survey 2.0, reinforces that affordability cannot be understood or addressed through price alone.”
“Patients defined affordability as the ability to consistently obtain their medications within their overall household budget, not as a fixed price point. Affordability thresholds varied widely, and many patients reported that the same medication shifted between being affordable and unaffordable over time due to changes in out-of-pocket costs.”
“Most notably, insurance-related barriers, not drug price, were the primary drivers of patient-reported unaffordability. In our survey, 95% of patients who stopped taking their medication and 72% who never started treatment cited insurance-related challenges such as coverage denials, cost-sharing, or barriers to financial assistance.”
“These findings underscore a critical point: policies that do not directly address insurance design, cost variability, and access to assistance are unlikely to reduce patient hardship.”
“We strongly support the board’s consideration of non-UPL alternatives and encourage prioritization of reforms that align with patient-reported drivers of affordability challenges.”
“In particular, policies that address misaligned incentives within the drug supply chain, such as delinking PBM compensation from drug prices and rebates, offer a more direct path to improving affordability and access. Reforms that realign these incentives, increase transparency, and ensure savings are passed through to patients are more likely to produce meaningful and sustained improvements.”