The EACH/PIC Coalition submitted comments to the Oregon PDAB, providing input into policy recommendations to consider for inclusion in the 2026 annual report to the legislature.
The letter stated:
“Throughout Oregon’s affordability review process, our coalition has encouraged the board to focus on policies that directly improve affordability and access for patients rather than pursuing price-setting approaches that primarily target system spending. We therefore appreciate the board’s intent to explore a broad range of policy options and particularly applaud its decision to prioritize alternative reforms instead of recommending Upper Payment Limits (UPLs).”
“First, we support efforts to improve patient affordability through reforms that make healthcare costs more predictable and manageable. Our survey findings demonstrated that affordability challenges are often driven by unpredictable and shifting out-of-pocket costs rather than the price of a medication alone. As a result, we encourage the board to support policies that directly improve cost predictability for patients, including out-of-pocket protections, cost-smoothing mechanisms, and other reforms that help patients better anticipate and manage healthcare expenses over time.”
“We also support policies that expand awareness of and access to financial assistance programs while ensuring that available assistance can be fully utilized by patients. Patients repeatedly reported that financial assistance often determines whether a treatment remains affordable. Accordingly, we support reforms that prohibit accumulator and maximizer adjustment programs and ensure that copay assistance counts toward deductibles and annual out-of-pocket maximums so patients receive the full benefit of available support.”
“Our survey findings consistently identified insurance design and healthcare system incentives as major contributors to affordability challenges. We therefore support reforms that protect patients from harmful utilization management practices, including prior authorization requirements, step therapy protocols, coverage disruptions, formulary changes, and non-medical switching. We encourage the board to support policies that improve transparency, strengthen patient protections, and ensure that cost-containment efforts do not disrupt access to effective treatments.”
“We also support efforts to better align incentives throughout the prescription drug supply chain. Policies that increase transparency, prohibit spread pricing, pass negotiated savings through to patients, and delink PBM compensation from drug prices represent meaningful opportunities to address affordability challenges without creating new barriers to care.”
“Finally, we encourage the board to continue incorporating patient perspectives into future affordability discussions. Patient experiences provide critical context that cannot be captured through pricing data alone. The board should also monitor the impact of any adopted reforms on patient access, including changes in formulary design, prior authorization requirements, step therapy utilization, and non-medical switching.”