The EACH/PIC Coalition submitted comments to the Oregon PDAB, providing input into affordability determinations, policy recommendations to address patient concerns, and the updated patient feedback form.
The letter stated:
Throughout the 2026 review process, EACH/PIC has encouraged the board to establish a clearer and more consistent framework for determining when a prescription drug presents an affordability challenge. As the board now enters final deliberations, we continue to believe that affordability determinations should be based on clear, understandable, and repeatable parameters that allow patients and other stakeholders to understand how the board reached its conclusions.
Most importantly, those parameters should reflect how patients actually experience affordability. As we have previously shared with the board, according to results from our Patient Experience Project, affordability is not determined by drug price alone. Patients experience affordability within the context of what they actually pay, their insurance coverage, cumulative healthcare expenses, access to financial assistance, and their ability to consistently obtain the treatment that works for them. Critically, the research found no single universal price threshold separated an affordable medication from an unaffordable one.
The same principle should guide the board’s policy deliberations. The ultimate measure of an affordability policy should be whether it meaningfully addresses the problems patients experience affording and accessing their medications.
As we noted in June, patient experiences point toward reforms that make healthcare costs more predictable and manageable, improve access to financial assistance, address harmful utilization management, and better align incentives throughout the prescription drug supply chain.
We appreciate the board’s continued consideration of policy options and look forward to learning more about the deliberations that have occurred over the past several months. We also encourage the board to provide patients and patient organizations with a meaningful opportunity to review and comment on proposed policy recommendations before they are incorporated into the final annual report.
Finally, we appreciate the board’s continued efforts to strengthen patient engagement. In particular, we applaud the decision to refine the patient feedback form and make it available throughout the year. Creating an ongoing opportunity for patients to share their experiences is an important step toward ensuring that patient perspectives inform the board’s work. We continue to believe, however, that the form can be improved to make participation more patient-friendly and to generate more informative responses. Carefully designed questions can help identify why a patient is experiencing affordability challenges, giving policymakers in Oregon better information to address the underlying causes of that hardship.