The EACH/PIC Coalition submitted a comment letter to the Maryland Prescription Drug Affordability Stakeholder Council (PDASC), providing input on determining appropriate policy interventions to address affordability concerns around Jardiance and Farxiga. The letter requested the Council’s assistance in ensuring that patient access and affordability remain central to all recommendations made to the Prescription Drug Affordability Board (PDAB).
The letter states:
“During their July meeting, the Maryland PDAB made the preliminary determination that both Farxiga and Jardiance present affordability challenges in Maryland. As the board and stakeholder council evaluate policy solutions to address the presumed affordability challenges, we urge both bodies to evaluate all potential policy tools, not simply move toward an Upper Payment Limit (UPL) as the default solution.“
“Our recent Patient Experience Survey: Prescription Drug Affordability and Unaffordability found that affordability challenges often stem from insurance design, access barriers, and the cumulative burden of managing chronic illness, not just the price of an individual drug. For that reason, a two-track approach is essential, one that considers other targeted reforms to address the underlying patient-reported problems alongside any price-based intervention.”
“While intended to reduce costs, UPLs can create new incentives for insurers and pharmacy benefit managers (PBMs) that may ultimately restrict patient access to needed medications. These include increased utilization management, formulary reshuffling, and adverse tiering, all of which can delay or disrupt treatment. As our survey results highlight, access delays and insurance rules, not cost alone, are often the true barriers behind “affordability” labels. Implementing a UPL without complementary protections risks worsening these challenges.”
“We urge the PDASC to take an active role in helping the PDAB evaluate which policy tools are best suited to address the problems patients have identified. This means starting with the “why” behind affordability concerns and selecting interventions that directly target those causes, whether that is reforming prior authorization processes, protecting copay assistance, or addressing underinsurance. A patient-centered, evidence-based approach will produce more effective and equitable outcomes than relying on a single blunt instrument like a UPL.”