The EACH/PIC Coalition submitted letters to the Maryland PDAB in response to proposed upper payment limits for Jardiance and Ozempic.
The letters stated:
We urge the board not to move forward with the proposed UPL since it does not directly address patient needs and alternative policy solutions have not yet been fully considered or evaluated by the board.
UPLs Do Not Guarantee Savings for Patients
We continue to 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. These shifts risk delaying or disrupting care, and as our Patient Experience Study has demonstrated, insurance barriers, not price alone, are often the real drivers of patient hardship and perceived “unaffordability.”
Furthermore, patients reported that treatments are not interchangeable and that accessing the correct medication is critically important for patients with chronic conditions. Therefore, while intended to reduce costs, implementing a UPL without complementary patient protections could worsen the very challenges patients already face.
We 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.