The EACH/PIC Coalition submitted comments to the Washington PDAB in advance of their March meeting. The letter provided feedback to the board on the affordability review process.
The letter stated:
“We urge the board to outline clear metrics and definitions for affordability for use in its drug cost reviews to ensure they are performed with consistency and a clear focus on patient benefit. 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 also urge the board to prioritize patient costs as a key aspect and focus of any affordability measurement, specifically patient out-of-pocket (OOP) costs. Furthermore, we urge the board to focus on patient-reported obstacles to care and address the underlying factors that contribute to patient hardship in affording and accessing their needed medications.”
“Our recent Patient Experience Project: Patient-Reported Affordability & Unaffordability Survey 2.0 aimed at better understanding why patients report medications affordable or unaffordable. Patients described the role of insurance coverage rules, cost-sharing structures, cumulative healthcare expenses, income, financial assistance availability, and changes in life circumstances in shaping their ability to remain on treatment over time. These contextual factors frequently determined affordability far more than the price of the medication itself.”
“While we understand that the board is limited by its statute in the policies that it can explore, we urge the board to consider that patient-identified barriers to their care are often not directly tied to the list price of medications. Failure to acknowledge this reality can result in policies that do not effectively reduce costs for patients. Worse yet, misapplied policy interventions could actually worsen the barriers that patients identify as obstacles to their care such as insurance driven out-of-pocket cost shifting and utilization management, including non-medical switching.”
“As the board solicits patient input on the drugs selected for 2026 review, we urge the board to reconsider its current patient survey, if the true intention is to determine patient-reported out-of-pocket cost drivers through meaningful data collection. As leaders in patient-facing prescription drug affordability data collection efforts, we are disappointed that the final survey reflects very few revisions despite substantial feedback from our organization on its design. Instead, the survey still relies on short, simplified questions that will not allow patients to provide meaningful context about their health needs or the real-world challenges they face in affording and accessing their medications.”
“Our coalition has worked to design and test patient questions that truly allow patients to share fully any barriers or obstacles they face when accessing their prescription drugs. The work has spanned 18 months and resulted in both a pilot study, the results of which shaped our feedback provided to the board last year, and released a final report in January 2026: the Patient Experience Project: Patient-Reported Affordability & Unaffordability Survey 2.0. Rather than relying primarily on yes/no or multiple-choice questions, the survey incorporated open-ended responses that allowed patients to explain their out-of-pocket costs, how those costs fit within their overall financial reality, and why they considered a medication affordable or unaffordable.“
“Our work on the Patient Experience Project was aimed, in part, to advise those conducting patient-facing data collection how to design questions that will produce substantive responses and accurate analysis. While straightforward to administer, the board’s survey will capture only a limited snapshot of the patient experience and will not produce meaningful data to inform the board about prescription drug affordability challenges for Washingtonians.”
“If the board’s intent is to put patient prescription drug affordability needs first, we strongly encourage the board to revise your current public surveys by referencing our new survey tool. Doing so would strengthen the quality of patient input collected during affordability reviews and better equip the board to fulfill its core purpose: identifying and resolving the real-world challenges patients report when trying to access the medications they rely on. Our coalition stands by your work to help patients afford their medications and will continue to offer our services to assist in making these important and necessary changes.”