On May 15, ASBM submitted comments to the Colorado Prescription Drug Affordability Board urging it not to impose an upper payment limit (UPL) on Cosentyx unless the Board can demonstrate that the policy will directly reduce patient out-of-pocket costs without disrupting access to treatment.

ASBM emphasized that a UPL would reduce the amount paid by insurers or pharmacy benefit managers (PBMs), but would not require those savings to be passed along to patients at the pharmacy counter. Many commercially insured patients already pay little or nothing for Cosentyx through existing copay-assistance programs, while patients who continue to face affordability challenges often do so because of deductibles, coinsurance, restrictive formularies, prior authorization, step therapy, copay accumulator programs, or specialty-pharmacy restrictions—none of which would be addressed by a UPL.

“A UPL that reduces reimbursement but leaves those mechanisms untouched would reduce spending and increase profitability for insurers or PBMs, while doing little or nothing for the patient,” the letter stated.

ASBM also warned that payment caps could prompt insurers and PBMs to impose new formulary restrictions or administrative hurdles, potentially disrupting stable patients who have arrived at an effective biologic therapy only after trying and failing other treatments.

The letter urged the Board to require enforceable patient pass-through protections, monitor formulary and utilization-management changes, protect patients from forced switching, and establish a process to suspend or revise any UPL if patient access worsens or savings fail to reach patients directly.

“The patient—not the PBM, not the insurer or another intermediary—should be the primary beneficiary of any cost-control measure,” the comments concluded.

Read the comment letter below: