Colorado PDAB has opportunity to lower drug costs, provide transparency

By

Shane Ersland

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Healthcare leaders continue to consider ways to make prescription drugs more affordable, and are hoping the Prescription Drug Affordability Board (PDAB) can make progress on that in Colorado.

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Experts discussed the PDAB, which the general assembly enacted in 2021, at the 2023 Colorado State of Reform Health Policy Conference last month. Colorado Pharmacists Society Executive Director Emily Zadvorny said drug costs influence a lot of the society’s work with patients. 

“Our optimal goal is to optimize medication outcomes, making sure what people are on works well,” Zadvorny said. “The problem is if people can’t afford them, they can’t work.”

PDAB Director Lila Cummings described the work the board is doing to try to make prescription drugs more accessible for Coloradans. 

“We heard over the past two years from consumers directly that prescription drugs (are) unaffordable,” Cummings said. “That’s a concern. So the work of the board is to understand which prescription drugs are unaffordable to Coloradans, and what can be done to increase access.”

Eight states have enacted PDABs, and some are permitted to set upper payment limits (UPLs) on drugs, including Colorado’s. 

“The (PDAB’s) two main duties are to conduct affordability reviews for prescription drugs, and if the board deems a prescription drug unaffordable, the board may establish a UPL for that drug,” Cummings said.

The board adopted a list of prescription drugs eligible for an affordability review on June 9th. There were 604 drugs that were eligible to be on that list, and PDAB elected to conduct affordability reviews for five: Enbrel, Genvoya, Cosentyx, Stelara, and Trikafta. 

“We’re now a little over two months into trying to conduct affordability reviews. The focus has been on patients and caregivers, and understanding from those individuals what their expertise (says) on whether or not these drugs are unaffordable for Coloradans. Other things the board needs to consider are access and comparing the cost effectiveness of a drug  compared to therapeutic alternatives.”

— Cummings

Katelin Lucariello, senior director of state policy at PhRMA, represents manufacturers of brand-name drugs for PDAB. She said many effective new medicines that are on the market in the US are not on the market in other countries. 

“About 46 percent of new medicines introduced on the market here are available in Canada,” Lucariello said. “That’s a significant difference in the number of medicines that are actually available. We benefit from more choice and faster speed to market. The state is limited to impacting the price of a medicine bought and sold in the states. What we’ve heard about the limited impact of a UPL, manufacturers included, is questioning how to implement a state-based UPL in a market that is national, where drug (prices) are typically negotiated.”

The issue presents a host of operational and implementation concerns, Lucariello said. 

“At this point in the process, we don’t have many answers for that,” she said. “The other roadblock in speaking to affordability is there’s a genuine interest in ensuring patients have affordable access to prescription medicine. Patients shouldn’t have to walk away from a pharmacy without having their prescription filled. But the UPL itself isn’t addressing a number of factors that are contributing to affordability.”

A UPL does not address affordability concerns like benefit design and high co-payments for specialty drugs, Lucariello said.

“Looking on the exchange, costs are upward of $750 [for some specialty drugs]. Arguably, that co-pay is going to be the same whether the patient is on a $10,000 specialty drug or a $30,000 specialty drug. Those are some of the hurdles patients are going to continue facing if we don’t look at this from a more holistic perspective.”

— Lucariello

Hope Stonner, policy manager for the Colorado Consumer Health Initiative, said the state’s PDAB has an important opportunity to develop transparency in drug cost setting, however.

“Stakeholders across the supply chain are getting an opportunity to justify why costs are so high,” Stonner said. “Which is really something that communities across the state have not had an opportunity to understand. We also know that transparency is not enough. Action is really necessary. It’s really expensive to be alive right now. People are having to make really impossible choices between paying for food, rent, and medication.” 

Zadvorny said some pharmacists are concerned about hidden costs that UPLs might drive.

“We were concerned about hidden costs that go into getting that medication to a patient,” Zadvorny said. “Oftentimes, these drugs are in an infusion process or are in specialty pharmacy areas. They’re not the kind you simply go to the pharmacy and get across the counter. So all the storage, compounding, monitoring, (and) administering of these drugs are costs. 

If pharmacies go under water, that’s not sustainable. The intent is not for any of that to happen, but it’s such a new process I think we’re all very conscious about trying to think of everything that needs to go into decisions that are made. And are we thinking about unintended consequences that could happen with a new process?”