The EACH/PIC Coalition submitted comments to the Oregon PDAB in advance of their October meeting on policies proposed for the annual report to the Oregon legislature. The letter followed up on recommendations made by the Coalition ahead of the September meeting and urged consideration of patient-driven policies.
The letter stated:
“As the board has experienced directly, a narrow focus on the cost of individual drugs is complicated, time consuming, and unlikely to solve prescription drug affordability challenges experienced by Oregonians.
“Effective health reform requires addressing structural drivers, insurance design, PBM incentives, and patient assistance, not isolated drug prices. Oregon has the opportunity to set a national example by advancing comprehensive, patient-centered solutions that strengthen the system rather than narrow its focus.”
“To create policies that truly improve affordability, reforms must address the system as a whole. We therefore reiterate the policy areas we supported in September:
1. Enact PBM Reform and Transparency
Hold PBMs accountable by eliminating spread pricing, delinking PBM compensation from drug prices, and requiring transparency so savings are shared directly with patients. These reforms target patient-reported drivers of unaffordability and would help ensure that affordability improvements are meaningful at the patient level.
2. Ensure Fair Reimbursement
Ensure that reimbursement rates and dispensing fees reflect the true costs of providing care. Pharmacies, infusion centers, and physician offices must be able to dispense needed medications without financial loss. Broadening networks and protecting fair reimbursement will preserve patient access—especially in rural and underserved areas.
3. Avoid Counterproductive Measures Like Upper Payment Limits (UPLs)
We continue to caution against UPLs, which cap what payers spend rather than what patients pay. Price setting measures are likely to trigger increased utilization management, formulary restrictions, or non-medical switching, worsening patient access without guaranteeing savings.”