Washington, D.C. — Yesterday, Consumers for Quality Care (CQC) submitted formal comments to the Senate Committee on Finance in response to its Request for Information (RFI) on prescription drug pricing, led by Ranking Member Ron Wyden. In its comments, CQC urged the Committee to address the insurer and pharmacy benefit manager (PBM) practices that have a direct impact on what patients ultimately pay at the pharmacy counter.

Prescription drug affordability remains one of the most urgent problems facing American families. Seniors, people managing chronic illness, and families and individuals with employer-sponsored and marketplace insurance can face significant out-of-pocket costs that make it harder to access the medications they need. CQC’s comments emphasize that this meaningful affordability reforms must address policies and practices that shape patients’ costs, including how insurers and PBMs design benefits, negotiate and retain rebates, manage formularies, and establish cost-sharing requirements.

“Patients experience prescription drug costs through what they are charged at the pharmacy counter, and too often it is difficult to understand how that price was determined,” said Jim Manley, CQC Board Member and former senior advisor to Senators Edward Kennedy and Harry Reid. “Congress has an opportunity to bring greater transparency and accountability to the practices that directly affect patients, including rebate retention, spread pricing, restrictive benefit designs, prior authorization, and step therapy.”

In its letter, CQC urged the Committee to prioritize reforms that would:

• Strengthen protections against excessive out-of-pocket costs, including ending copay accumulator programs that prevent cost-sharing assistance from counting towards patients’ deductibles and out-of-pocket maximums;
• Require greater PBM transparency around rebate retention, spread pricing, formulary decision-making, and compensation, so negotiated savings reach patients instead of padding PBM profits;
• Scrutinize insurance benefit design, including high coinsurance, restrictive formularies, prior authorization, and step-therapy “fail first” policies that can delay or restrict access to care recommended by a patient’s doctor; and
• Continue examining the effects of vertical integration on competition and strengthen oversight of insurer practices involving Medical Loss Ratio requirements, affiliated businesses and inflated in-network charges.

“Real affordability reform should start with the patient and follow dollars through the healthcare systems,” Manley added. “Patients shouldn’t need a law degree and an accounting background just to understand why they are paying a certain amount for a medication. We appreciate Ranking Member Wyden’s leadership on this RFI and urge the Committee to advance comprehensive, patient-centered reforms that bring greater transparency, accountability, and savings to patients.”