On Friday, the Colorado Prescription Drug Affordability Board (PDAB) unanimously approved the eligible drug list that will be subject to its review process for establishing upper payment limits (UPL) on prescription drugs.
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The list contains hundreds of drugs that were chosen based on the approved selection criteria: the total utilization of the drug, the wholesale acquisition cost, the annual per-patient out-of-pocket cost, the total paid amount, and the annual average amount paid per person.
The Division of Insurance (DOI) will collect data on the course of treatment, pharmacy/medical claims, inflation-adjusted costs, and market alternatives related to each drug on the list and present the information to the PDAB at its June 23rd meeting.
The board updated its review process timeline with input from stakeholders and the Prescription Drug Affordability Advisory Council (PDAAC) scheduled to be heard prior to its first potential affordability review on Aug. 4th. DOI anticipates at least four affordability reviews could be conducted to determine if a drug is unaffordable by year’s end.
The general assembly passed two bills this past session impacting the PDAB’s work.
House Bill 1225 extends the PDAB’s sunset from 2026 to 2031 and expands the number of UPL drugs the board can designate through next year from 12 to 18. It expands the review process to consider all drugs with a wholesale acquisition cost of $3,000 or more or a course of treatment costing $30,000 or more per year.
The 2023-2024 Long Bill provides additional funding for the board to continue its work, including strengthening databases and pharmacoeconomics expertise to support the UPL process. Board members expressed satisfaction with the new statutes and the opportunity to have a greater impact on affordability.
“I’m really looking forward to the expanded databases and having the better data,” said board member Amarylis Gutierrez, PharmD. “The better data we have, the better decisions we’re going to make. And also to get pharmacoeconomic expertise—that’s going to be really helpful so that we make the right decisions. It’s really going to impact the direction in which we’re going.”
Lila Cummings, prescription drug affordability director at DOI, told State of Reform last month that while health equity impact is considered an important criterion by all involved in the process, data limitations prevent it from being weighed stronger.
“As outlined in the board’s rules, there are multiple ways where the board may examine health equity in the context of prescription drugs,” Cummings said. “Board staff plan on presenting the [PDAB] with a health equity metric in June, which begins to shed light on potential health equity implications associated with use of prescription drugs. This is one data point that begins to shed light on health equity implications, but is not the full story of health equity implications.”
DOI will utilize the Social Vulnerability Index (SVI) score, a CDC measure of social vulnerability that factors in issues like poverty, housing, and transportation, to determine health equity impact by calculating the percentage of users of a prescription drug that live in counties with scores below the state average SVI.
SVI is limited because it does not necessarily reflect a patient’s circumstances or a drug’s impact across different communities, according to DOI. While SVI remains the only available health equity metric for board members to consider in this initial selection of UPL drugs, the division has communicated it will work to expand health equity data collection in the future.
The board will be working closely with the PDAAC over the coming fiscal year on establishing prescription drug affordability policy recommendations for next session.
During the meeting, officials laid out potential topics the board could look into for future policies, including the role of group purchasing organizations in the prescription drug supply chain, research into unaffordable drugs treating multiple indications, and the impact of utilization management and prior authorization requirements on prescription drugs.