Maryland PDAB

Comment to the Maryland PDAB on proposed amendments to COMAR 14.01.04 Cost Review Study Process, addressing the MCDB ERISA data blind spot, MDPN/IRA inclusion criteria, the risk that foreign data introduces QALY-based methods prohibited by the ADA, and the need for greater patient-centered focus.

Written comment to the Maryland PDAB on patient outreach concerns, the Board's mixed Farxiga (no UPL) and Jardiance (proposed UPL) decisions, and the moral and ethical concerns of testing UPL implementation on state mental health facilities and university health plans.

Public statement from Jen Laws, President & CEO of CANN, responding to the Maryland PDAB's mixed Jardiance and Farxiga decisions, and urging state leadership to require demonstrated patient access protections before policies are finalized.

Written comment addressing Maryland PDAB's March 2026 meeting on implementation concerns missing baseline data and need for non-UPL affordability solutions.

Testimony on Maryland PDAB's flawed cost review study process and incomplete policy review methodology at February 2026 informational hearing.

Written comment addressing Maryland PDAB's January 2026 meeting concerns about affordability challenges and data gaps in the cost review process.

Comment on Maryland PDAB's affordability challenge determinations, addressing methodology concerns, patient impact considerations, and recommendations for more transparent processes.

Comment on Maryland PDAB's data contracting decisions, raising concerns about data source selection, transparency in affordability analysis, and compliance with statutory requirements.

Comment addressing Maryland PDAB meeting agenda, raising ongoing concerns about data transparency, patient engagement, and affordability determination methodology.

Comment on Maryland PDAB meeting materials addressing ongoing concerns about board operations, data transparency, and patient engagement in affordability determinations.

Comment opposing expansion of Maryland PDAB authority, citing lack of monitoring requirements, fiscal impacts on 340B programs, and insufficient patient protections in the proposed legislation.

Comment expressing concerns about Maryland PDAB's emergency rulemaking process, unmet statutory obligations regarding monitoring metrics, and inadequate patient engagement in board operations.

Six-page comment opposing Maryland's proposed Upper Payment Limit Action Plan, citing lack of patient focus, insufficient monitoring metrics, potential harm to safety-net providers and Medicaid, and recommending alternative affordability approaches.

Comment opposing Maryland's selection of Biktarvy for PDAB affordability review, explaining antiretroviral non-interchangeability and PBM profiteering as root affordability issues.