The EACH/PIC Coalition submitted a comment letter to the OR PDAB on the subset list of drugs and insulin products selected by the Oregon board for further review and the broader affordability review process.
The letter stated:
“We remain concerned about the board’s lack of clear criteria in developing the subset list of drugs under review and lack of safeguards in place to consider negative impacts of the cost review process on patient access. … By relying solely on cost as the basis for selection, the board risks unintentionally targeting treatments for specific populations. Any unintended consequences of the review process—including increased utilization management or restricted access—may then fall disproportionately on already vulnerable groups and further exacerbate health disparities.”
“We remain concerned that a 30-day public comment period to provide input on 27 medications is not adequate. As we noted in our previous letter, such a short window limits meaningful participation from patients, caregivers, and patient advocacy organizations. … We also note that survey response numbers presented during the last meeting were extremely low, often in the single digits. These response levels are insufficient for drawing meaningful conclusions about patient experiences and should prompt further outreach and engagement efforts.”
“The board’s work must be centered on the real-world challenges patients face in affording and accessing their prescribed medications. A narrow focus on systemic or payer-level costs overlooks the most meaningful measure of affordability: whether individuals can obtain and adhere to the medications they need. We urge the board to take the time necessary to ensure that the cost review process does not disrupt continuity of care or restrict treatment options. Patients must not bear the burden of unintended consequences stemming from policy decisions that limit access or add new layers of complexity to their care.”