The EACH/PIC Coalition submitted comments to the Oregon PDAB in advance of their January meeting. The letter urged caution as the board makes finalizes its 2025 drug review and provided recommendations for improvements to the drug review process for 2026.
The letter stated:
“As the board finalizes its determinations on the 2025 drug review, we continue to urge caution given the persistent lack of clarity around the methodology used to assess affordability. … We fear that the board is prioritizing completion of the review over executing a meaningful evaluation of patient affordability, despite the fact that these determinations could impact patients who rely on these medications.”
“We appreciate the opportunity to engage with the board as it begins its 2026 drug review process. As the board looks ahead, we believe it is important to reflect on lessons from the past two review cycles. The board’s experience over the past two cost review cycles underscores the importance of aligning scope, methodology, and capacity.”
“First, we urge the board to evaluate its approach to focus more centrally on identifying and addressing patient concerns with prescription drugs. … Patient costs must remain the focal point of affordability reviews, but those costs cannot be evaluated in isolation. Assistance programs, insurance design, and coverage limitations all significantly shape what patients ultimately pay and whether they can access their medications at all. Failing to weigh these factors risks drawing incomplete or misleading conclusions. Additionally, reliance on claims data that is even two years old threatens the relevance and accuracy of affordability assessments as new biosimilars and generics come on the market and new policies like caps on drug copays and other policy measures are implemented.”
“At a minimum, as the board plans for 2026, we strongly encourage limiting the scope of review to a smaller number of drugs. The volume of drugs reviewed in 2025 compressed timelines, overwhelmed deliberations, and made meaningful patient participation difficult. Comment deadlines requiring feedback on dozens of drugs within 30 days were not reasonable for patients, caregivers, or advocacy organizations. A narrower scope will support more rigorous review, improve transparency, and better incorporate patient perspectives.”