The March meeting of the Maryland Prescription Drug Affordability Board (PDAB) ignited significant concerns among a broad group of patient, physician, pharmacist and caregiver organizations.
Recent legislation requires the PDAB to conduct an analysis on the impact of upper payment limits on patient access, patient cost and several other factors in its annual report after the upper payment limit has been in effect for at least a full year.
Board members pushed back against these new elements in its required reporting, stating that “no one reads” government outcomes analyses and that others “generally don’t care what the report says.”
Additionally, when reviewing elements of their cost review reports, some argued that “minutia” shouldn’t stand in the way of getting things done and the board should hastily “move along” after barely half an hour of discussion.
These dismissive comments are deeply troubling for those relying on the board to use sound judgment when affecting access to life-saving medications.
Rushing the Process
For patients whose health is directly impacted by PDAB policy decisions, the apparent eagerness to rush the review process is a concern. Advocates have called for a thoughtful process, but these remarks convey a troubling message: that speed may be prioritized over thoroughness.
The Value of Care Coalition stated in its formal letter to the Maryland PDAB, “For patients whose health and quality of life depend on these decisions, 34 minutes of discussion on a drug review is hardly excessive—it is, in fact, the bare minimum for a decision of such magnitude.”
While some board members also raised thoughtful questions as the discussion unfolded, and stakeholders were no doubt encouraged by a call for the use of complete, specific data, the urgency to conclude the process is troubling. With such consequential decision-making in front of them, the board has an obligation to act with great care.
Avoiding Accountability
At each step in the PDAB’s processes, stakeholders have warned about unintended consequences resulting from the implementation of upper payment limits. These concerns are underscored by recent reports indicating payers may restrict access to treatments and independent pharmacists may not stock drugs subjected to price controls.
Comprehensive impact analyses are a common tool for public transparency and would allow the PDAB to evaluate its own effectiveness. Such reporting could also alert policymakers if upper payment limits do indeed lead to access challenges. These reports are not bureaucratic burdens but vital accountability tools.
A Familiar Problem
Unfortunately, this is not the first time Maryland PDAB members have offered concerning sentiments. Previously, board members have stated they are “seeing diminishing returns” on public comment and that, rather than having a well-developed plan, they’re “writing the playbook” as they go. They’ve conceded they may not get it “100% correct” and, despite the reports highlighted above, wondered aloud how price caps could negatively impact access.
Prioritizing Patients
Rather than prioritizing expediency over accountability and haste over rigor, the PDAB should embrace a more deliberate, transparent, and stakeholder-responsive approach as it moves forward. Patients’ access to life-sustaining medications should never be a foregone conclusion or an afterthought in the policy-making process.