- The Department of Health & Human Services’ plans to reduce out-of-pocket patient costs and address rising drug costs is on the right track, but requires some fixes to better guide patients when purchasing their medications, according to a recent opinion letter from the Patient Access Network.
Written alongside 52 other patient advocacy organizations, the letter responded to the recent drug pricing blueprint published by HHS in late May. The blueprint called on payers and drug manufacturers to drive better price transparency for drug costs and proposed regulatory changes that could quell the rising cost of prescription drugs.
PAN and its co-signatories were specifically concerned with patient access to prescribed treatments. High drug costs can often be prohibitive, which in turn can considerably harm medication adherence. A patient who cannot afford her medication won’t be taking that medication, the letter asserted.
"When patients cannot afford their therapies, they cannot be adherent to their treatment plans, which can increase the total cost of care for these patients over time,” the signatories wrote. “Such an outcome hurts patients, their families and taxpayers—all who bear the burden of the higher cost of care."
It will be essential for all cost-cutting proposals concerning the prescription drug industry to continue to include safety-net subsidies that support underserved patients, the letter added. Currently, the HHS blueprint does not go far enough to address these patient needs, PAN and its co-signatories said.
“Our organizations wish to underscore that patient assistance programs provide a much-needed safety net for so many patients—in both commercial and publicly funded health plans—who simply cannot afford the ever-growing costs of their medications,” they wrote.
“Until all patients have affordable, unencumbered access to the therapies they need, patient assistance programs must continue their critically important work of giving much-needed financial support to patients who require costly medications to maintain or regain their health, well-being and quality-of-life.”
Other comments on the blueprint’s request for information (RFI) called on HHS and other related entities to offer patients access to more and better information about their medications and associated costs. This information must be both actionable and understandable.
However, HHS should be wary of placing too much decision-making responsibility on patients alone, PAN and its co-signatories cautioned.
“Navigating the healthcare system often proves frustrating, confusing and problematic for too many patients, particularly those with serious, life-threatening, chronic, complex and disabling conditions,” they stated.
“As such, while we appreciate the Department’s interest in boosting consumerism in healthcare, we have concerns regarding placing too much responsibility on patients. Shifting complicated decision-making onto beneficiaries cannot be a substitute for oversight.”
That is not to say there is not a place for some patient responsibility in both price shopping and cost-sharing. PAN and the rest of the patient advocate coalition recognize the benefits of patients having some “skin in the game” financially.
But data has indicated that pushing too much financial responsibility can keep patients from purchasing their medications. Additionally, leaving patients to navigate different prescription drug cost deals and safety-net support programs can leave patients drowning in a convoluted process.
Instead, HHS and related entities must make it simple and seamless for patients to identify the best medication option and purchase that medication.
The letter also addressed different topics that could help patients obtain access to lower-cost medications. Initiatives to promote prescription drug price transparency, establishing out-of-pocket maximums for Medicare Part D, and moving some Medicare Part B drugs to Part D are some of the proposals listed in the letter.
The signatories also recommended provisions to support better transparency between patient and pharmacist, including getting rid of so-called pharmacy gag clauses. These clauses keep pharmacists from directing their patients to lower-cost drug options because of certain payer agreements.
The patient advocate coalition also recommended HHS begin research on the causes of medication non-adherence among patients. Research should look at solutions to those problems and the way in which those factors influence underserved patient populations.
The groups also warned HHS about making regulatory changes without evidence. This would mean that HHS has the evidence-based research to confirm that any changes could reduce drug spending for patients.
The signatories concluded with a promise to continue working alongside HHS to lower prescription drug costs and increase patient access, two principles that are important to the groups, according to PAN President and CEO Dan Klein.
"Patients are the top priority for all of the patient advocacy groups that have signed the letter," Klein said in a statement. "We agree with HHS that we need to change the system in a way that promotes the development of affordable innovations that improve health outcomes and lower both out-of-pocket cost and the total cost of care."