Weekly Policy Update: CBSA Comments on 2020 Drug Price Transparency Draft Legislation 

Weekly Policy Update: CBSA Comments on 2020 Drug Price Transparency Draft Legislation 

On Monday, CBSA sent a comment letter to Rep. Dominique Jackson and Rep. Dylan Roberts outlining our comments on their draft legislation on prescription drug price transparency. While CBSA appreciates the bill sponsors’ work on this bill and their commitment to a stakeholder process, we have several concerns that we hope they will consider and address.

CBSA strongly opposes the bill’s requirement for 90 days advance notice of a price increase, which could have serious consequences for the drug supply chain and the competitive market. In our letter, we urge the bill sponsors to remove this provision or at least revise the requirement to only one day advance notice of an increase to mitigate any unintended consequences. We are also concerned that the bill, as written, does not include adequate protections for confidential or proprietary information and have outlined specific considerations we hope will be addressed.

Lastly, CBSA continues to advocate for policies to share rebates with patients at the point of sale, and we were disappointed that this provision was not included in the draft legislation. We know that in our current system, patients with high deductible health plans and high coinsurance are often exposed to high out-of-pocket costs because their costs are tied to the list price. Studies have shown that sharing rebates with those patients at the pharmacy counter could significantly reduce their costs, with minimal impact on premiums. We hope the bill sponsors will include this policy in the legislation, as it is the only provision in the bill that will actually help patients access the medicines they need.

CBSA also attended a stakeholder meeting on Monday to discuss the draft legislation and convey our concerns and recommendations to the bill’s sponsors.

CBSA’s full comment letter can be found here.

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