The International Society for Pharmacoeconomics and Outcomes Research is asking members to submit their feedback on the Health and Human Services’ recent call for comments on the Trump administration’s drug pricing blueprint.
ISPOR says it would prefer members focus their comments on sections it picked from the “HHS Blueprint to Lower Drug Prices and Reduce Out-of-Pocket Costs,” including:
- Cost-shifting, as can be caused by the Medicaid best price restrictions, has the potential to distort resource utilization and result in inefficient care – is there evidence of this actually having happened due to Medicaid best pricing?
- Evidence – and the uncertainty inherent in it – about relative efficacy, immunogenicity, and tolerability, and how they may affect treatment patterns (e.g., when cycling is relevant) need to be available for informed decision-making, especially when there are not large differences in pricing.
- While some of the specific price reporting issues discussed here may not be relevant, a discussion of value-based arrangements in general could provide good context here.
- The potential benefits of aligning price with indication to encourage cost-effective utilization can be described here.
Comments from all members are welcome, including international membership.
ISPOR says responses are due by Monday, June 25.
