Blueprint to Lower Drug Prices and Reduce Out-of-Pocket Costs

By: Brandon M. Macsata, CEO, ADAP Advocacy Association

In May 2018, drug pricing took center stage as the U.S. Department of Health & Human Services released its proposed Blueprint to Lower Drug Prices and Reduce Out-of-Pocket Costs. It what has been characterized as "a way forward in fight against mushrooming costs,"[1] HHS has set the stage for an extremely important debate...and likely the most contentious battle on health policy since passage of the Affordable Care Act.

Photo Source: NBC WPSD-6

According to the Notice published in the Federal Register, HHS' blueprint covers multiple areas including, but not limited to:[2]

• Improving competition and ending the gaming of the regulatory process,
• supporting better negotiation of drug discounts in government-funded insurance programs,
• creating incentives for pharmaceutical companies to lower list prices, and,
• reducing out-of-pocket spending for patients at the pharmacy and other sites of care.

Comments on the blueprint were due on or before July 16, 2018.

The ADAP Advocacy Association endorsed two coalition letters submitted to HHS.

One letter, spearheaded by the Patient Access Network Foundation (PAN), "cautions against HHS undertaking policy changes without evidence-based research. HHS must be confident that any changes it makes will have the intended positive impact on individuals and families, with no unintended consequences that could harm patients and make prescription drugs less affordable and accessible."[3] PAN's letter was signed by 52 patient advocacy organizations, representing millions of patients with serious, life-threatening, chronic, complex and disabling conditions.

The other letter was a collaborative effort led by the HIV Health Care Access Working Group (HHCAWG), which represents over 100 national and community-based HIV service organizations representing HIV medical providers, public health professionals, advocates, and people living with HIV who are all committed to ensuring access to critical HIV- and Hepatitis C-related health care and support services.

We have compiled a listing of the comments submitted by some other organizations, which are available to download here:

• AIDS United
• American Academy of HIV Medicine (AAHIVM)
• Biotechnology Innovation Organization (BIO)
• HIV Health Care Access Working Group (HHCAWG)
• National Alliance of State & Territorial AIDS Directors (NASTAD)
• Patient Access Network Foundation (PAN)
• Pharmaceutical Care Management Association (PCMA)
• Pharmaceutical Research and Manufacturers of America (PhRMA)
• Southern AIDS Coalition (SAC) 
• Southern HIV/AIDS Strategy Initiative (SASI)
• The 340B Coalition
• Treatment Action Group (TAG)
• 340B Health

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[1] Aronson, Lauren (2018, July 13). Blueprint to Lower Drug Prices could offer a way forward in fight against mushrooming costs. The Hill. Retrieved online at http://thehill.com/blogs/congress-blog/healthcare/396883-blueprint-to-lower-drug-prices-could-offer-a-way-forward-in.
[2] A Notice by the Health and Human Services Department (2018, May 16). HHS Blueprint to Lower Drug Prices and Reduce Out-of-Pocket Costs. Retrieved online at https://www.federalregister.gov/documents/2018/05/16/2018-10435/hhs-blueprint-to-lower-drug-prices-and-reduce-out-of-pocket-costs.
[3] Naples, Maggie (2018, July 17). National Patient Advocacy Organizations Come Together to Respond to the HHS Blueprint to Lower Drug Prices and Reduce Out-of-Pocket (OOP) Costs. Patient Access Network Foundation. Retrieved online at https://panfoundation.org/index.php/en/about-us/media-room/national-patient-advocacy-organizations-come-together-to-respond-to-the-hhs-blueprint-to-lower-drug-prices-and-reduce-out-of-pocket-oop-costs.

Rhode Island Advocates Score 'YUGE' Victory Against Insurance Company Gimmicks

By: Brandon M. Macsata, CEO, ADAP Advocacy Association

Last month, advocates in the Ocean State fought back against proposed legislation in the Rhode Island General Assembly that would have prohibited patients from utilizing manufacturer coupons and drug discount cards to lower their out-of-pocket drug costs. S.2532 was a thinly veiled threat orchestrated by the insurance companies and other private health plan payers, which would have resulted in patients paying more for their prescription drugs. Such gimmicks disproportionately impact people living with chronic health conditions who rely on specialty drugs, such as HIV/AIDS or Hepatitis C.

In early March the legislation was introduced in the Rhode Island General Assembly and referred to the Senate Health and Human Services Committee. The Committee, however, ultimately recommended the measure be held for further study after strong pushback from the HIV community (and others).

On March 27th, opponents testified against S.2532 during a hearing convened by the Committee. The HIV Health Care Access Working Group (HHCAWG) — which is part of the Federal AIDS Policy Partnership (FAPP) — also sent a letter opposing S.2532, and the state legislators took notice.

Manufacturer coupons and drug discount cards, commonly known as accumulator adjustment programs, were highlighted in a recent ADAP Blog, "Rx Drug Coupon Concerns Pit Prices Against Patients." The smoke and mirrors being perpetrated against patients is fueled by the insurance industry's misinformation, as well as their hopes that most patients don't take the time to read, and let alone understand, their policy documents.

Photo Source: Patients Rising

The AIDS Institute (TAI) has been actively monitoring efforts by insurance companies to restrict access to care and treatment for people living with HIV/AIDS — including efforts to limit accumulator adjustment programs. Carl Schmid, TAI's Deputy Executive Director, summarized concerns over limiting such programs:

“It is already difficult for people living with HIV and others who want to take PrEP to access their medications due to insurance benefit practices such as high co-insurance and deductibles, this will just compound the situation. It is time for us to be loud and strong, and fight back. People lives are on the line.”

What happened in Rhode Island was a victory for people living with HIV/AIDS, as well as patients in general. But this issue isn't going away any time soon.  The ADAP Advocacy Association has expressed strong concern over the ongoing gimmicks by the insurance industry and health plan payers on this policy issue.

Related articles of potential interest:

• Opponents: Bill limiting drug coupons, discount cards would endanger lives, published on 03/28/18 in the Providence Journal
• New Let’s Talk About Cost ads highlight how copay accumulator programs could leave patients financially exposed, published on 03/27/18 in The Catalyst.
• Have You Heard of the Co-Pay Accumulator, published on 03/26/18 in Patients Rising.
• Copay Accumulators: Costly Consequences of a New Cost-Shifting Pharmacy Benefit, published on 01/03/18 in Drug Channels Institute