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November 14, 2023
On behalf of the Greater Boston Chamber of Commerce and our 1,300 members, I write to offer comments on S.2499, An Act relative to pharmaceutical access, costs and transparency. One of the Chamber’s guiding health care policy principles is that the state must strike a balance between supporting our cornerstone health care industry and ensuring that world-class care is accessible and affordable for residents, businesses, and the state budget.
The Chamber supports the goal to include pharmaceutical manufacturing companies and pharmacy benefit managers (PBMs) in health cost trends analyses and hearings. Including both in Health Policy Commission (HPC) public hearings and Center for Health Information and Analysis (CHIA) reporting will provide useful data and analysis to aid in health care cost reviews. Steps like permitting the HPC to study drugs can support qualitative and quantitative analysis about whether costs are justified.
While the Chamber strongly supports expanding public hearings and data analysis, it is necessary to emphasize the exceptional cooperation that results in regular, voluntary appearances in which private entities (including hospitals and health plans) discuss their products, services, and operations in public settings. With that in mind, the Chamber opposes required disclosure of detailed information on their businesses, like marketing expenses, research and development expenses, and capital funding expenses – which may undermine the competitiveness of these institutions by disclosing key proprietary information to competitors. It is unclear how this additional information would reduce health care costs, whether for specific companies, sectors, or the industry as a whole.
The Chamber also urges the Senate to take caution in any attempt to curb cost sharing for certain drugs. In the cases of both price setting and eliminating cost sharing, health care costs are not reduced. Instead, those costs are shifted to increased premiums, making health insurance more expensive for employers and employees alike.
As with any comprehensive legislation, the Legislature should consider the impacts this bill will have on our broader economy. We urge the Senate to avoid adopting amendments that will only add to health care costs broadly, and specifically, costs to employers, including self-insured, and employees in sponsored plans. These considerations are particularly relevant because health care plays an integral role in our regional and state economy. In Massachusetts, the health care industry directly accounts for 17 percent of jobs in the state and indirectly accounts for tens of thousands of additional jobs. The industry here includes world class providers, pharmaceutical breakthroughs, and among the largest share of insured residents in the country.
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