State Drug Price Transparency & Reporting
State Price Transparency & Reporting continues to be a concern for many pharmaceutical manufacturers.
Today there are 21 states that have passed price reporting laws. This clearly highlights that states remain at the forefront of evolving reporting regulations for manufacturers. The pressure for manufacturers to stay compliant with reporting requirements goes beyond multiple laws and associated thresholds for price reporting. The implications of this dynamic environment are that even in states with enacted laws, submission templates change year over year. In addition to that, the mechanism through which they must report also changes over time as states move from email submissions to online portals.
The Challenges in State Price Transparency & Reporting
The task of monitoring legislation is an arduous process. However, the subsequent need to track changes that states make to existing laws and reporting mechanisms also requires continuous monitoring. In the last year 15% of states with existing legislation have made updates to their reporting operations. Nevada, a state with enacted legislation since 2017, updated the triggers that lead to reporting for manufacturers. Each year Nevada will publish a list of drugs with significant WAC increases (10-20%) that require reporting. Manufacturers are only required to submit a report if any of their drugs appear on the list. Changes like this are often communicated clearly. However, what is far less publicised is when states make changes to the templates that they require manufactures to submit.
This year the state of Washington, known for its robust reporting program, updated their reporting templates. As a result different data needs to be reported to the state than previous years. On November 15th, they also decommissioned their existing reporting portal and created a new portal for data submission. While these updates can be found on individual state websites, the changes are not widely shared or communicated. Updates like those made in Washington require manufacturers to monitor not only updates to laws but also individual state websites quarterly.
The Solution for State Price Transparency & Reporting
The dynamic nature of state price reporting underscores the value of utilising a dedicated IT solution. One of the benefits is the ability to store all reporting requirements in one place. Another advantage is to stay in contact with states for updates on submission processes. Receiving automated notifications about new or existing legislation can also help.
For more details on drug price transparency submissions and requirements or details about our in-house solution, please reach out to our team at Marbls.