Following years of fits and starts for Prescription Drug Affordability Board (PDAB) operations, advocates might be surprised to find that two states now seem to be in a race to implement processes for setting upper payment limits.
In early September, PDABs met in both Colorado and Maryland. Though each listed a discussion about upper payment limit (UPL) rulemaking on their agendas, the conversations were quite different.
Let’s take a look at Colorado:
In Colorado, the PDAB held a joint meeting with its Advisory Council. This resulted in robust discussion amongst all members, which led the PDAB Chair to pose the following question: Should the Board slow down to put together a more comprehensive process for setting the upper payment limit?
Despite public acknowledgement from a Board member that the effects of upper payment limits are unknown, the group’s sentiment was twofold – don’t slow down but do the process as well as they can. After all, they said, we may never know the outcomes until we do it and, in the meantime, the status quo isn’t working.
What’s that mean…and is it good enough for patients?
Accepting that the Board will not know how public policy will impact patient care is alarming. It’s clear the PDAB takes the feedback it receives from stakeholders with a grain of salt – the Chair, again, discounted views from patient organizations despite major questions about patient savings and access remaining unanswered. A survey of health plans showed clearly that plans expect negative impacts for patient access and out of pocket cost.
That said, much of the meeting was then devoted to the consideration of a predictive model that could produce potential outcomes based on the manipulation of certain variables (think: different UPLs). This idea gained traction but building it, ironically, is likely to slow the process.
We will learn in future meetings whether or not the PDAB will move forward with modeling or whether they’ll move more quickly without it. Tune in October 18 at 2PM MDT to learn more.