The EACH/PIC Coalition submitted a comment letter to the Maryland Prescription Drug Affordability Stakeholder Council (PDASC) providing input on the implementation of upper payment limits (UPLs) in Maryland. 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:
“We urge the council to assist the PDAB in obtaining concrete information from all sectors of the healthcare marketplace—manufacturers, insurers, pharmacy benefit managers (PBMs), and providers—regarding how they will respond to the implementation of a UPL. The decisions of any one of these actors could influence whether patients continue to have access to critical medications. If even one stakeholder responds by limiting availability or access due to the constraints of a UPL, the result could be disruptions to continuity of care and increased burdens on patients and providers alike.”
“As deliberations continue, we urge the council to recommend that the PDAB define affordability from the patient perspective, prioritizing patient out-of-pocket costs as a key metric. We strongly encourage the PDAB to incorporate patient-reported financial burdens and access challenges into ongoing affordability determinations.”
“In addition to financial considerations, we urge the council to assist the PDAB in identifying and addressing the underlying, patient-reported obstacles that contribute to affordability challenges. A failure to address these root causes could result in policies that produce limited or uneven benefits, helping some patients while leaving others behind. The PDAB has emphasized time and again that UPLs might not be the correct way to address affordability. We urge the council to ensure that, when affordability challenges are identified, the policy response appropriately addresses the underlying cause.”
“Finally, we continue to emphasize the importance of directly incorporating patient input into the cost review process. The council is uniquely positioned to help the PDAB strengthen its methods for gathering patient feedback. … Given the far-reaching implications of UPL implementation, we respectfully ask the council to support a thoughtful, transparent, and patient-centered approach.”