Meeting Public Comments

Kathleen Arntsen [Lupus and Allied Diseases Association, Inc.]

Please see attached comments.

Brian Henderson [Coalition of State Rheumatology Organizations ]

The Coalition of State Rheumatology Organizations (CSRO) is a national organization composed of over 30 state and regional professional rheumatology societies, including our member society that represents providers of rheumatology care in Iowa. CSRO was formed by physicians to ensure excellence and access to the highest quality care for patients with rheumatologic, autoimmune, and musculoskeletal disease. It is with this in mind that we write to you in support of SF 86.As you consider SF 86, CSRO would like to convey its support for providing continuity of care to stable patients. Nonmedical switching occurs when health plans and Pharmacy Benefit Managers (PBMs) force a stable patient to switch from their currently effective medication by restricting coverage for that medication. Health plans and pharmacy benefit managers accomplish this by: removing the drug from their formulary, moving the drug to a more restrictive formulary tier, or using other prevailing means to increase the patients outofpocket costs for the drug or restrict access. Patients that suffer from complex chronic conditions, such as rheumatoid arthritis and many others, require continuity of care to successfully manage their condition. The aforementioned conditions are extremely complex and present in a variety of ways, necessitating a high degree of individualized and attentive care. Physicians may spend months or years of trial and error finding a treatment regimen that properly manages their condition. The resulting course of treatment must carefully balance each patients unique medical history, comorbid conditions, and sideeffect balancing drug interactions. This equilibrium is carefully chosen and tenuous. Even slight deviations in treatment and variations between drugs, even those in the same therapeutic class, can cause serious adverse events. Aside from needless suffering, the resulting disease progression can be irreversible, life threatening, and cause the patients original treatment to lose effectiveness. It cannot be assumed that a treatment that works for one patient will work for each patient. Nonmedical switches are onesize fits all decisions that disrupt physicians ability to exercise their medical expertise in concert with their patients.It must be noted that CSRO is not unconcerned with the cost of pharmaceuticals in the United States. However, nonmedical switching is a poor way to control costs for the patient populations in question, and can lead to larger followon costs that swamp any upfront savings. Physicians, pharmacists, and other healthcare administrators have reported that nonmedical switching increases administrative time, increases side effects or new unforeseen effects, and increases downstream costs to plans. Moreover, when a stable plan enrollee is switched for nonmedical reasons, their care is more likely to be interrupted by a second switch. These costmotivated switches increase plan enrollees health care utilization, disrupt the course of care, and, as a result, increase related health care costs. For these reasons, CSRO requests your support for SF 86. We appreciate your consideration of our comments.