Rx Disclosure Report shows climbing Rx drug costs, inconsistent reporting

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In 2021, the ND Legislative Assembly enacted HB 1032, creating a prescription drug price transparency program to be administered by the N.D. Insurance Department. It went into effect in Q3 of 2021, and required prescription drug manufactures, pharmacy benefit managers, and health insurers to disclose information about the cost of prescription drugs.

An analysis conducted by AARP Research evaluating the contents of the first four quarters of the North Dakota Drug Manufacturer’s Price Disclosure Reports showed substantial inconsistencies in reporting that make it challenging to follow the intent of this legislation – collecting good data that will serve as the basis for policy making and understanding moving forward. It is very important to note that this is a single year’s worth of data. While we are refraining from and cautioning against broad generalizations at this time, some initial findings are worth sharing.

Summary of Results

• The total number of drugs reported by quarter was uneven – illustrating that manufacturer compliance to the new Rx regulation is inconsistent.​

• Only about half of drugs included in the database were reported across all four quarters – highlighting that manufacturer reporting was variable in the program’s first year of operation. ​
• Trending of reported drugs among consecutive and new and/or non-consecutive drugs again illustrates inconsistencies in manufacturer reporting. ​
• Manufacturer participation in the drug transparency program trended downward after the first quarter and ended the first full year with 117 fewer participating manufacturers. 

The primary reporting element is an 11-digit code – which is clearly stated in the instructions for manufacturers. Only two-thirds of reporting entities used that required protocol correctly. The review shows that often reporting entities entered only seven, eight, nine, or ten digits of that code – making data matching very challenging.

Despite the inconsistencies, some information can be discerned from the analysis:

• Pfizer had the greatest number of drugs that showed a price increase.
• Nine of the ten manufacturers who reported price increases increased the prices of at least half of the drugs they manufacture.
• The greatest price increase in reported trade drugs was for Tudorza, a prescription drug inhaler manufactured by AstraZeneca and used to treat chronic obstructive pulmonary disease (COPD) in adults. It increased 74% ($424) from $571 to $995.
• The greatest increase in reported generic drugs was rizatriptan benzoate, a migraine medication manufactured by Unichem Pharmaceuticals. It increased 78% ($13) from $16 to $29.

In support of their work implementing the program, AARP ND shared these findings with the ND Insurance Department as well as House and Senate leadership. As noted earlier, this data is in its infancy. Moving forward manufacturers, PBMs and insurance companies need to provide cleaner and more consistent information. Without good data, it’s difficult to develop policy solutions that best address the ongoing struggle many North Dakotans face in affording their prescriptions.

To learn more, watch Aisha Cozad, AARP Senior Research Advisor, explain the analysis.