Public Comments for 01/14/2025 Labor and Commerce
HB1724 - Prescription Drug Affordability Board established; drug cost affordability review.
January 24, 2025 Chairman R. Creigh Deeds Commonwealth of Virginia Senate Finance and Appropriations Committee Health and Human Resources Subcommittee Committee Re: VA HB 1724 - Health and Human Resources Subcommittee Committee Dear Chairman Deeds: Aimed Alliance is a not-for-profit health policy organization that seeks to protect and enhance the rights of healthcare consumers and providers. Aimed Alliance urges the Appropriations - Health and Human Resources Subcommittee to consider how a prescription drug affordability board (PDAB) may impact patient access and consider alternative legislation that will directly address health care affordability for consumers. Legislation to establish PDABs aims to control the rising costs of prescription drugs by setting caps, known as upper payment limits (UPL) for select prescription drugs. Currently, no state PDAB has completed the drug selection and UPL-setting process. As such, PDABs are experimental initiatives with significant upfront costs that provide no guarantee that any cost-savings generated from these programs will lower costs for health care consumers. Importantly, UPLs restrict the amount that payers reimburse pharmacy benefit managers (PBM) for prescription drugs. As such, without specific requirements to pass UPL savings to consumers, these savings may not impact what consumers pay at the pharmacy counter. Given the uncertainty regarding whether PDABs will effectively lower costs for consumers, Aimed Alliance urges the Subcommittee to consider alternative legislation for directly reducing consumers’ out-of-pocket expenses, such as PBM reform. PBMs are middlemen who negotiate with manufacturers to determine which medicines will be included in health insurance companies’ formularies and how much plans will pay the manufacturers for those medicines. PBMs also determine consumers’ cost-sharing requirements for medications. These practices are often opaque and lack transparency, which results in payers negotiating payments without a full understanding of the actual cost of the medications. Consequently, regulating PBM activities by requiring additional transparency in pharmacy steering, prescription drug costs, and rebate pass-through requirements presents an opportunity to address key factors that impact costs within health insurance. If the Subcommittee moves forward with the HB 1724, Aimed Alliance urges the Subcommittee to ensure that the PDAB is required to prioritize patient input by (1) including a consumer or patient representative on the Board, (2) mandating ongoing consumer engagement, and (3) requiring that UPL-derived cost savings be passed on to patients. In conclusion, Aimed Alliance urges the Subcommittee to consider alternatives to PDABs that can directly impact consumer access and affordability. Moreover, we urge the Subcommittee to ensure that any PDAB legislation provides a permanent, consistent, and genuine process for valuing patient, caregiver, and provider perspectives and lived experiences. Sincerely, Olivia Backhaus Staff Attorney
Attached, please find public comment on behalf of the Derma Care Access Network.
Tigerlily Foundation is a national women’s health and oncology organization dedicated to education, advocacy, and hands-on support for young women before, during, and after cancer. We focus on eradicating disparities of age, stage, and color. Today, I write to express our organization’s concerns about HB 1724, which would establish a prescription drug affordability board (PDAB) in Virginia. While the intent of this legislation may be to address rising drug costs, implementing a PDAB could unintentionally create barriers to essential medicines, particularly for patients with cancer and other chronic conditions, worsening existing health inequities all while failing to provide any cost savings to patients. Policies linked to PDABs, such as upper payment limits (UPLs), often fail to protect timely and effective care. Instead, UPLs limit reimbursements for hospitals, doctors, and pharmacists who dispense critical treatments, making it harder for patients to access medications. This could force Virginians to seek care elsewhere or forgo treatment entirely, leading to adverse health outcomes, including higher medical costs in the future. To date, PDABs have not demonstrated direct cost savings for patients. As Tigerlily ANGEL Advocate and Virginia resident Vickie Williams emphasizes: “Affordability is crucial. Everyone should be able to afford the drugs that save their lives. UPLs do NOT make drugs more affordable for PATIENTS.” We must address drug affordability without creating new barriers. Additionally, establishing a PDAB could deter research and development of new medicines, limiting treatment options for patients with few or no current alternatives. As Tigerlily ANGEL Advocate Erica Fae explains, innovation is critical: “I’m healing from metastatic breast cancer, and there are limited options for me. I’m currently on a new immunotherapy drug, which significantly improves my quality of life. Without it, my only alternatives are harsh chemo and hormone blockers. PDABs create barriers that prevent patients like me from accessing lifesaving and life-improving medications.” Any proposed PDAB must include diverse patient perspectives and advocacy organizations to ensure that recommendations reflect the needs of all stakeholders. For patients like those we serve and our own CEO & Founder Maimah Karmo, who was diagnosed with triple-negative breast cancer (TNBC), an aggressive cancer more common in Black and Hispanic women, timely and equitable access to physician-prescribed treatments is vital. Drug price controls risk unintentionally blocking access to innovative medicines that improve survival and quality of life for patients battling life-threatening conditions. While we commend Virginia’s efforts to address healthcare access and affordability, HB 1724 does not achieve these goals and could have unintended consequences, particularly for those who already face significant barriers to care. TNBC, among other conditions, disproportionately impacts these populations, and a PDAB could worsen disparities in care, hinder innovation, and limit future treatment options for all. On behalf of Tigerlily Foundation and the communities we serve, we urge you to reconsider HB 1724. We thank you for your leadership and consideration of our concerns.
Dear Chair Sickles and Members of the House Appropriations Health and Human Resources Subcommittee, On behalf of the Virginia Association of Hematologists and Oncologists (VAHO) and the Association for Clinical Oncology (ASCO), I'm sharing a letter outlining concerns that upper payment limit language in HB 1724 would jeopardize access to necessary care for patients with cancer. Please let me know if you have any questions - we're happy to be a resource. Best, Sarah Lanford
On behalf of the people living with cystic fibrosis (CF) in Virginia, the Cystic Fibrosis Foundation writes to provide comments on HB 1724. We appreciate the need to improve affordability of care for Virginians and address rising costs to ensure sustainability of the state’s health care system. However, the paramount goal must be preserving access to care and therapies for people living with a disease, and we caution that Prescription Drug Affordability Boards (PDAB) may be working towards two separate aims that require separate consideration and policy solutions: reducing drug costs for the state of Virginia and reducing drug costs for consumers. Policies that cap reimbursement for drugs may not ultimately impact what Virginians pay at the pharmacy counter and it is important that the state recognize this distinction as it proceeds with this legislation. We also recommend additional provisions to HB 1724 as outlined in our letter to ensure the PDAB puts the needs of people living with a disease, including CF, at the center of the discussion when selecting drugs for affordability review, conducting affordability reviews, or considering upper payment limits.
I’m attaching my experience with Colorado’s PDAB. As a patient who is impacted by these deliberations, I strongly urge you not to approve HB1724. So far, Colorado has spent millions only to realize that there will be no savings from the PDAB or UPL process. Studies are now showing that not only will we not see savings, our access to medicine could be harmed through increased barriers like step therapy, prior authorization, and formulary changes. Other measures like PBM reform, making all copays count, and plan benefit design reform would be far less expensive and directly impact our out of pocket costs. Please don’t pass a PDAB and throw taxpayer money away.
TO: Appropriations Committee FROM: Melissa Gong Mitchell, Executive Director, Global Coalition on Aging SUBJECT: Letter Submission: House Bill 1724 To Honorable Members of the Virginia General Assembly Appropriations Committee, We write to you today to share the attached letter of our concern around this legislation. As written, HB 1724 stands to negatively impact Virginia patients, taxpayers and the life science industry in the Commonwealth by creating a prescription drug affordability board (PDAB) that will waste taxpayer money, stifle biotech innovation and fail to deliver savings for patients in need. Please do not hesitate to contact us if the Global Coalition on Aging / Alliance for Health Innovation can be a resource to you and your staff. Thank you for the opportunity to share our concerns with the Committee. Sincerely, Melissa Gong Mitchell Executive Director, Global Coalition on Aging
Please let me know about anything to do with ANY SOLAR or wind. Also why aren't you working on lowering this socialism health obamare that is failing! We pay double our house payment for healthcare. They do a certain percentage of what u make a year. I have to take money out of my 401k for healthcare that counts as income. It shouldn't count as income when you are taxing the heck out of us. We can't travel,most our prescriptions we use to take won't be covered and could go on and on about this robbery of people s hard earned money!
I’m writing today in hopes that Virginia can avoid the grave mistake Colorado made enacting the costly prescription drug affordability program. To date, our state has allocated over 2 million dollars and saved zero. In addition, they’ve put patients through a hellacious process evaluating whether their insurance should cover disease treatment. Recently, the Colorado PDAB changed its focus from saving patients money to possibly saving on premiums. This means they know that very little savings, if any, will be seen by the people who need the medications AND they understand a UPL is not the avenue to help us actually afford medication. Recently there has been a study of payers that confirmed that not only will we not see savings, the UPL will most likely increase healthcare disparities, change coverage across the entire class of medications, and even make treatment hoops harder to jump through. The UPL doesn’t address the “rebate” model that our drug supply chain uses. These keep drug pricing high, so insurers base formularies on rebates rather than cost effectiveness. A UPL doesn’t encourage an insurer to cover the drug, because they’ll make less money. Independent pharmacies will be unable to stock and distribute these medications because they won’t be able to take the loss - but giant PBMs can. Since the patient doesn’t benefit from the UPL, the question becomes -who does? That answer is monopolistic PBMs. They are the sole benefactor of any UPL placed. Companies like Arnold Ventures, ICER, and PORTAL who are pushing for single payer healthcare systems that discriminate against the elderly, disabled, and chronically ill are the big companies pushing for the PDAB and UPL. These groups have been associated with eugenics rhetoric and that is NEVER a good look. Please avoid the dire mistake Colorado has made and DO NOT form a prescription drug affordability program. There are other ways to help truly cut healthcare costs that don’t funnel drug rebates into large PBMs. Please consider things like banning maximizers and accumulators, capping out of pocket copay costs, PBM reform, and making sure all copays count.
On behalf of the Cystic Fibrosis Research Institute (CFRI), which provides services to those impacted by cystic fibrosis across the US, including in Virginia, and as the mother of an adult living with cystic fibrosis (CF), I write to express our concerns regarding HB 1724, a bill to establish the Prescription Drug Affordability Board (PDAB) in the State of Virginia. We respectfully request that the House Labor & Commerce Committee oppose the legislation, as it has the potential to restrict access to rare disease medications, in particular Trifakta, and reduce access to crucial therapies. As a community with very complex chronic medical issues, those impacted by cystic fibrosis know very well that the cost of health care is far too high, and we applaud the intent to lower costs to protect patients and their families. However, we are concerned that there is no carve out for rare disease medications – including Trikafta – and that these drugs will be judged under the same lens as a medication that can treat hundreds of thousands of people. Please see attached letter.
My name is Kelsey Haddow; I am a lifelong Virginia and I am the Director of Patient Engagement for the Rare Access Action Project or RAAP whose priority is to help ensure rare disease patients have access to the care and treatments they need. In states across the country, including in Virginia, RAAP has been clear that PDABs are not an effective means by which to lower patient out-of-pocket costs. Rare patients are spending their valuable time in those states defending their right to access their therapies. That time should be spent caring for themselves or those they care for. Today, on behalf of RAAP, I am asking you to oppose Virginia House Bill 1724. The reintroduction of PDAB legislation in 2025 represents a significant step backward for Virginia. This renewed attempt at government price controls ignores the evidence of harm such measures cause, particularly to patients with rare diseases. These boards impose arbitrary price controls that fail to account for the complexities of patient access to therapies, especially for treatments targeting rare and orphan diseases, where the stakes are often life or death. PDAB champions would declare victory by imposing the upper payment limit (or state price control), but because of the interconnected nature of the healthcare marketplace, products costing more than the UPL would be pushed out of reach for patients. Rare Disease and other patients would be left to pay the difference. For patients with rare and chronic conditions, affordability is only part of the equation. They need assurances that the therapies they depend on will remain available and that future innovations will continue to address unmet medical needs. RAAP and other advocacy stakeholders have identified several initiatives that can reduce or stabilize the amount patients pay out of pocket for their therapies. These solutions can include: Encouraging capped out-of-pocket copay alternatives in the individual insurance marketplace. Broadening access to Medicare Part B products for beneficiaries under age 65 PBM transparency reforms Copay accumulator, maximizer, and AFP reforms to protect patients from out-of-pocket costs Public/Private Risk pooling for at-risk high-cost patients RAAP urges lawmakers to reject this flawed PDAB experiment once again and prioritize reforms that genuinely lower patient out-of-pocket costs without compromising access to critical treatments. We are hosting a Webinar this evening that I have sent you an invite to and I encourage to attend to learn more about what PDABs do to the rare and chronic disease community. We encourage legislators to vote no on VA HB 1724.
Attached, please find public comment from the Derma Care Access Network.
Coalition letter in opposition to HB 1724.
Honorable Members of the Virginia House Committee on Labor and Commerce: Tigerlily Foundation is a national women's health and oncology organization dedicated to education, advocacy, and hands-on support for young women before, during, and after cancer, with a focus on eliminating disparities of age, stage, and color. On behalf of the patients and families we serve, I write to express deep concerns about HB 1724, a bill that proposes establishing a Prescription Drug Affordability Board (PDAB) in Virginia. While affordability is a priority for all, PDABs create additional barriers to care, especially for patients managing cancer and other complex conditions. PDABs often enforce upper payment limits (UPLs), restricting reimbursement to hospitals, doctors, and pharmacies that provide critical medications. These policies, instead of making treatments more affordable, force patients to search for alternative providers or delay treatment entirely. For patients with cancer, such delays can lead to disease progression or even death. To date, no PDAB has resulted in direct savings for patients. As Tigerlily ANGEL Advocate and Virginia resident Vickie Williams explains: “As someone with four chronic conditions, affordability is crucial. Everyone should be able to afford the drugs that save their lives, whatever the insurance. UPLs do NOT make drugs more affordable for PATIENTS.” We must find ways to reduce costs without creating new barriers to access. Beyond affordability concerns, PDABs threaten medical innovation. Patients with limited treatment options rely on continued advancements in medicine. HB 1724 could discourage investment in lifesaving drug research by creating price uncertainty. As Tigerlily ANGEL Advocate Erica Fae, a Virginia resident living with metastatic breast cancer, shares: “Innovation & new drugs are critical. I'm currently taking a new immunotherapy drug. My only alternatives are harsh chemo & hormone blockers. My quality of life would diminish greatly without this drug. PDABs create barriers that prevent patients like me from accessing treatments that improve both survival and quality of life.” It is also essential that any healthcare policy prioritize representation. A PDAB should include patient voices and advocacy organizations to ensure diverse populations are heard—especially Black and Brown communities disproportionately impacted by health inequities. Conditions like Triple Negative Breast Cancer, which affects Black women at younger ages and later stages, underscore the need for timely and equitable access to treatment. While we applaud Virginia lawmakers for working to address affordability and health disparities, HB 1724 risks deepening inequities and limiting access to care for vulnerable populations. On behalf of the patients and families served by Tigerlily Foundation, I urge you to reconsider this legislation and seek solutions that reduce costs without compromising access or innovation. As an 18-year survivor of TNBC and a Virginia resident, I thank you for your leadership on this issue. Please feel free to contact me at maimah@tigerlilyfoundation.org if Tigerlily Foundation can assist in developing patient-centered solutions. Sincerely, Maimah Karmo President & CEO, Tigerlily Foundation
My name is Scott Bertani, and I bring over 28 years of experience as a long-term consumer of HIV services and an advocate for health equity, and as Director of Advocacy for HealthHIV. PDABs, as seen in other states like Colorado, provide valuable lessons in implementation. Key challenges include ensuring that affordability measures, such as Upper Payment Limits (UPLs), do not unintentionally disrupt the financial stability of programs and rebate ecosystems that sustain safety-net providers like Federally Qualified Health Centers (FQHCs) and AIDS Drug Assistance Programs (ADAPs)—each with its own working principles and capacity to support under-resourced systems. These programs are critical for underserved communities, including People with HIV (PWH). By adopting a patient-focused approach, Virginia can ensure that affordability efforts not only reduce costs but also protect access to care. Patients and their families should be at the center of any affordability initiative. PWH and those managing chronic conditions often face barriers such as high deductibles, prior authorizations, and restricted pharmacy networks (including required mail-order pharmacies). A successful PDAB framework must address these real-world challenges. Including patient voices in the decision-making process and ensuring meaningful engagement with the communities most affected will improve outcomes and foster trust in the system. Recommendations: To ensure affordability efforts align with maintaining access and equity, we recommend: 1. Including patient and community stakeholder representation on the PDAB to ensure decisions reflect the needs of those most impacted. 2. Establishing carve-outs or protections for HIV treatments and other essential medications to preserve access for individuals dependent on these therapies, particularly in states with communicable disease statutes and higher concentrations of statute usage, to avoid further restricting access. Notably, Washington State successfully implemented a carve-out through a legislative proviso in its 2022 state operating budget, demonstrating a viable model for ensuring community access. 3. Ensuring stability for covered entities operating within programs such as 340B, 330, and 318, as well as ADAP and its contractors, to continue leveraging the rebates they generate to support critical services, including the purchase of health insurance for PWH. This includes Federally Qualified Health Centers (FQHCs), ADAP contractors, and all other covered entities within these programs, ensuring their ability to sustain care delivery and provide essential services independently and effectively. 4. Focusing on reducing out-of-pocket costs for patients while maintaining access to critical treatments, recognizing the unique role HIV ecosystems play in leveraging rebates to address unmet needs. 5. Prioritizing shared clinical decision-making between providers and patients to safeguard individualized care and improve health outcomes. 6. Ensuring that Quality-Adjusted Life Years (QALYs) are not part of the lexicon or methodology used in evaluating drug affordability. This metric, which assigns value to lives based on perceived "quality," disproportionately impacts people with chronic conditions like HIV and undermines equitable access to care.
Dear Chair Ward, Vice Chair Herring and Honorable Committee Members, On behalf of the Immune Deficiency Foundation (IDF), and the community affected by primary immunodeficiency (PI) in the Commonwealth of Virginia, I write to you to provide comments and express opposition to HB1724, establishing a Prescription Drug Affordability Board (PDAB). My name is Matt Prentice, and I am the Director of State Policy with IDF and a resident of Virginia Beach. IDF is dedicated to improving the diagnosis, treatment, and quality of life of people impacted by PI by fostering a community empowered by advocacy, education, and research. Individuals with PI have one of the over 450 rare disorders in which a person’s immune system fails to function properly because of genetic or intrinsic defects. They are highly susceptible to recurrent, persistent, and severe infections, which, without treatment, can lead to organ damage and often require significant interventions and hospitalization. Fortunately, most people with PI can live healthy, productive lives if they receive lifelong immunoglobulin replacement therapy, an innovative and lifesaving therapy derived from donated plasma. Although well-intentioned, we are concerned about the unintended consequences that a PDAB and specifically the determination of an Upper Payment Limit (UPL) may have on access to critical medications. Affordable healthcare requires solutions that address holistic factors that influence what patients pay. Rebates, negotiations, and pharmacy benefit fees are just some of the factors that influence the actual cost of any specific medication. These influences are interconnected, whereas an UPL is solely focused on one piece. We are concerned about the impact a UPL will have on reimbursement rates and the downstream impact on patient access. If pharmacies are reimbursed at rates below acquisition costs, this may limit their ability to provide specialty drugs. To date, PDABs in other states have not generated any savings. Additionally, if one does, it is unclear whether any savings would be passed on to patients. The potential for patients to lose access to medications, because of an effort not designed to directly lower their costs, is unacceptable. We urge you to oppose HB1724 and pursue alternative solutions to increase affordability and lower out-of-pocket costs for Virginians, without the risk of compromising their access to lifesaving medications. Matt Prentice, Director of State Policy with the Immune Deficiency Foundation
On behalf of our member companies and the pharmaceutical supply chain, the Healthcare Distribution Alliance (HDA) would like to share our strong concerns with HB 1724, Prescription Drug Affordability Board. HDA is the national trade association representing pharmaceutical wholesale distributors, the vital link between more than 1,200 pharmaceutical manufacturers and more than 330,000 pharmacies and other healthcare settings nationwide, including over 5,800 sites of care in Virginia. As you may know, distributors operate a unique role in the supply chain. They do not set list prices, determine reimbursements, or play any role in determining the amount patients pay for medicines. Rather, distributors are the logistical experts in the supply chain who ensure products are physically on pharmacy shelves where and when patients need them, by executing manufacturer contracts and physically fulfilling pharmacy orders. As a representative of such logistical experts within the supply chain, HDA would like to share our concerns regarding the harmful impact on the physical supply chain in Virginia that a Prescription Drug Affordability Board with the ability to set UPLs would have. While HDA supports the state’s efforts in seeking a better understanding of the prices that consumers see at the pharmacy counter, state-level UPLs on the purchases and reimbursement of drugs do not adequately reflect that prescription drugs are bought and paid for in the U.S. A state-level UPL, especially a UPL following federal MFP limits, would place caps on in-state purchases but not out-of-state purchases, ultimately limiting the ability of points of care to recoup costs for administering or dispensing these products. This could result in Virginia sites of care being unable to stock these medications. It is also important to note that while MFP represents the most that Medicare will pay for a drug, it does not change the “list price” of drugs, as set by manufacturers, or the complex national system in which prescription drugs are purchased and distributed from a manufacturer to a wholesaler, then to a healthcare provider, and finally to a patient. Reductions in price to CMS will likely be achieved through a number of federal actions, which cannot be adequately replicated at the state level. In summary- HDA is concerned that establishing a Board which is empowered to set UPLs would ultimately create costly disruptions to Virginians' access to critical pharmaceuticals, and we respectfully oppose HB 1724.
The Alliance for Health Innovation (Alliance) represents diverse stakeholders, including patients, providers, caregivers, biopharmaceutical innovators, and business communities, all committed to promoting healthy aging and fostering innovation in healthcare. Led by the Global Coalition on Aging (GCOA), the Alliance advocates for policies that support a thriving healthcare sector, enabling Virginians and others to live longer and healthier lives. We are writing today to express our serious concerns about the potential establishment of a Prescription Drug Affordability Board (PDAB) in Virginia and the unintended consequences it could have on patient access to critical treatments. We understand the desire to address prescription drug affordability, especially for older adults and those facing chronic or complex conditions. However, we are concerned that introducing Upper Payment Limits (UPLs) through a PDAB will create significant barriers to access, especially for innovative and often more expensive medicines. The attached letter outlines our concerns in more detail. We appreciate your commitment to improving healthcare access for Virginians and invite you to engage with us further on these important issues. Thank you for your time and consideration. We would be happy to have a follow-up conversation to discuss these concerns.
Please see attached written testimony.
On behalf of the Virginia Association of Hematologists and Oncologists (VAHO) and the Association for Clinical Oncology (ASCO), I'm sharing a letter outlining concerns with HB 1724 ahead of today's hearing (attached). We are concerned that the upper payment limits would jeopardize access to necessary care for Virginia patients with cancer. Please let me know if you have any questions about cancer care - we are happy to be a resource.
I am writing on behalf of the Community Oncology Alliance (COA), and the seventy independent oncology clinics we represent across the commonwealth. We write to express our opposition to the proposed establishment of a Prescription Drug Affordability Board (PDAB) and the impact of an Upper Payment Limit (UPL) on community oncology in Virginia. My name is Dr. Mark Thompson and I serve as Medical Director of Public Policy for the Community Oncology Alliance (COA). COA is the only nonprofit organization in the United States dedicated solely to independent community oncology practices, which serve the majority of Americans receiving treatment for cancer. Community oncology clinics deliver high-quality cancer care often at a fraction of the cost of treatment delivered in other settings. That is why we share the assembly’s enthusiasm for reduced healthcare costs. However, we believe the implementation of a UPL as proposed in this legislation, may have severe repercussions for Virginians living with cancer and the community practices that serve them. The insufficient reimbursement of oncology drugs, as a result of an upper payment limit, places a significant financial burden on independent practices. This burden hinders their ability to meet the high costs associated with delivering quality patient care while also maintaining the essential infrastructure necessary for optimal treatment within local communities. We strongly advise against the imposition of a UPL especially when such limits do not meet the acquisition price that community oncology and other specialty practices pay to acquire these medications. Independent practices cannot sustain themselves when they are forced to pay more for drugs than the reimbursement they receive, and the policies that cause this burden jeopardize the existence of our practices. If this bill is allowed to become state statute, it will create additional financial burdens for community practices, adding to reduced competition in Virginia. This in turn, will limit patient choice and increase healthcare costs across the board. As a result, Virginians living with cancer will have no other option but to seek treatment in hospital settings. As you are aware, hospitals often operate at higher costs than independent practices, and the consequent shift in cost burden will fall upon taxpayers and patients. COA urges you to reconsider this policy, safeguarding the continued viability of independent practices and ensuring Virginians maintain access to affordable cancer care in their communities. In closing, while the intention behind this legislation is admirable, the imposition of an upper payment limit will have unintended and detrimental consequences for Virginians and the independent practices that serve their communities. This, in turn, will impact patient access to quality cancer care and will contribute to the ongoing challenges of market consolidation in the commonwealth. COA and our members respectfully urge you to oppose this bill and explore an alternative approach that secures affordability without compromising the stability of the state’s cancer care infrastructure. If you have any follow up questions or would like assistance on any issue involving independent oncology practices, please contact COA director of state regulation and policy, James Lee at jlee@coacancer.org. Sincerely, Mark Thompson, MD Medical Director of Public Policy Community Oncology Alliance (COA)
The purpose intended is written commentary regarding concerns about HB 1724.
VAHO Position Statement re: PDABs
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