Aimed Alliance provided feedback on Maryland’s Prescription Drug Affordability Board’s draft regulations, COMAR 14.01.0 and COMAR 14.01.05, which amend and establish rules on the Board’s procedures, policy review, and upper payment limits (UPL). Aimed Alliance’s comment focused on how the proposed UPL methodology only considers total out-of-pocket costs for state, county, and municipal health plans, as well as Medicaid and excluded patient costs.
The letter urged the Board to consider patient out-of-pocket costs in setting UPLs and implementing a monitoring process to understand how a UPL may impact patient access. Additionally, the letter requested the removal of provisions allowing the Chair or staff designee to limit repetitious testimony during informal hearings, as this could silence important patient concerns. Read the letter here.
Last Updated on February 28, 2025 by Aimed Alliance
