The US Department of Health and Human Services’ (HHS) final rule requiring inclusion of price into all televised direct-to-consumer (DTC) advertising for pharmaceuticals reimbursable under Medicare/Medicaid that have a cost greater than $35 per month was supposed to begin this July, but manufacturers may have won a reprieve with an initial court ruling that HHS overstepped its bounds. The rule would have required that the price, reflective of a month of therapy for chronic or a typical course of therapy for nonchronic drugs, must be displayed in legible text at the end of the advertisement. A disclaimer stating, “If you have insurance that covers drugs, your cost may be different” would be allowed. Even though this rule may not be implemented, recent surveys with leading patient stakeholders have found support for more price transparency, meaning this issue is not going away. How can manufacturers respond if something similar to the HHS rule were implemented in the future?

Price changes, particularly increases, would be an issue in an era of full price transparency. Manufacturers, especially with products in competitive categories, may consider minimizing price changes to once a year and attempt to align the change with other products in the category. Manufacturers could also modify the DTC ad or launch a new one entirely when the price changes to highlight new data or give the impression that the updated price reflects something new.

Including costs in DTC ads or other venues means that messaging priority may need to shift while staying within the confines of the advertisement requirements. More emphasis on patient support programs would be beneficial. On the non-DTC side of the business, manufacturers should reinforce patient support programs to pharmacies and providers. HUB programs can be reinforced as an avenue for providers to send prescriptions directly to consumers to ensure that patients are accessing support programs and lessen the risk of patient abandonment out of concern for cost.

Even the best HUB program cannot be expected to catch every patient. Identifying and addressing abandonment of care will be a responsibility shared across the industry. Pharmaceutical manufacturers can help both payers and IDNs by identifying risk factors for abandonment and providing these stakeholders with strategies to address the issue. For IDNs and health systems, developing algorithms in the EHR to flag certain combinations of demographic and disease information as indicating a higher risk of abandonment can lead to proactive engagement. For payers, the claims system may identify gaps in refilling pharmaceuticals as well as ICD-10 codes that do not have corresponding pharmaceutical treatment. Manufacturers can provide payers with information on relevant codes and which gaps may constitute abandonment.

The constant changes in the healthcare landscape require pharmaceutical marketers to be nimble and adaptable. Pricing in DTC is just one of the possible changes. The purpose of DTC remains the same: to educate and empower patients and providers to seek better care. Adding price does not change that. Although the HHS rule may be dead for now, manufacturers can take these lessons as a way to adapt in a market with more transparency.