The EACH/PIC Coalition submitted comments to the Oregon PDAB ahead of their April meeting, providing feedback on the current Request for Information (RFI) process, public engagement opportunities, and the overall direction of the cost review framework.
Among other issues, the letter urged the board to extend the deadline for patients to provide input on the subset list of medications by an additional 30 days to allow adequate time for patients to participate. Additionally, the letter requests additional information on how patient feedback will be sought and utilized in the ongoing cost review process.
The feedback in the letter includes:
“We are concerned that the current 30-day comment period to provide feedback on 27 medications is not sufficient. More time is required to ensure patients, caregivers, and organizations can meaningfully contribute to the review process and provide feedback on the medications included in the subset list. We respectfully urge the board to extend the public comment period to a minimum of 60 days to allow meaningful participation from patients, caregivers, and patient organizations.“
“We understand that the cost review process includes a public comment component once the
nine drugs and one insulin product are selected. We urge the board to ensure these comment
periods are clearly announced in advance and that at least 45 days are provided for input.
Comment periods should be accompanied by broad outreach from the board and state agencies to ensure patients and organizations are aware of their opportunity to weigh in.”
“We continue to encourage the board to center cost reviews around the lived experiences of patients and the real-world affordability challenges they face. A review that focuses solely on systemic or payer-level costs risks overlooking the most meaningful aspect of affordability: the context behind affordability concerns, including the impact on people’s ability to access and adhere to their prescribed medications.”