In the second edition of our analysis “Update: Effect of state prescription drug affordability boards (PDABs) and upper payment limits (UPLs) on the drug pricing ecosystem,” we find that UPLs would not help states with PDABs achieve their intended goals of reduced patient out-of-pocket costs and lower state drug spending, and could create unintended negative consequences, such as reduced access, a larger patient out-of-pocket burden and reduced reimbursement for providers.
However, several state PDABs continue to pursue UPLs, despite facing significant procedural challenges, including the inability to establish what “affordability” means; difficulty in defining who benefits; using inconsistent methodology and not incorporating the complexities of the supply chain into the process.
The findings of the 2025 research analysis suggest that, rather than delivering cost savings to patients or state budgets, UPLs may destabilize the broader drug pricing ecosystem and not help patients or providers.
This analysis was conducted by Johnson & Johnson’s Center for U.S. Healthcare Policy Research. It is an update to an original 2024 paper titled “Influence of Prescription Drug Affordability Boards and Upper Payment Limits on the State Drug Pricing Ecosystem.” For more information on the analysis, methods and limitations, see the full report: Johnson & Johnson Innovative Medicine. Update: Effect of state Prescription Drug Affordability Boards (PDABs) and Upper Payment Limits (UPLs) on the Drug Pricing Ecosystem. The Center for U.S. Healthcare Policy Research. August 2025. Available from: https://policyresearch.jnj.com/influence-of-prescription-drug-affordability-boards-and-upper-payment-limits-on-state-drug-pricing
© Johnson & Johnson and its affiliates 202510/25 cp-532459v1