340B Can Be Hard to Parse. Especially for AI

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THE ARC/ I Asked AI for Some 340B Insights. I Got Back Beautiful Garbage

It’s a Friday, and it’s been a long week. 

There’s plenty of news summarized below, but I want to take a fun aside and talk about AI first. 

Believe it or not, there is a lot of 340B chatter out there that I don’t write about. Most of it is local-level stuff, and I’ve found that the majority of that content is either op-eds with Astroturf vibes or news coverage that’s just not up to the task of dissecting the program in all of its absurdities. 

But I began to wonder, earlier this week, if I might be missing something. Are local newspapers running more editorials and opinion pieces around 340B that -- when considered in aggregate -- showcase some sort of broader trend? 

So I asked ChatGPT. This is what I got back … a list of publications and dates and headlines and URLs and sentiment:

Wow, I thought. I’m missing a groundswell of local-level pushback. 

But. 

Every single line of this is wrong. None of these publications ran editorials on 340B. Not only were the headlines made up, but the URLs were hallucinated. 

I remain AI-curious, but I make sure that AI-generated output doesn’t get anywhere near my actual work, either here or for clients. And the 340B misadventure is yet another reminder that generative AI tools have enormous shortcomings that make them a poor replacement for human insight. 

Perhaps that will change, and perhaps that change will come sooner than we all expect. 

But, for now, if you want high-level thoughts on 340B, you’re stuck with my uniquely, um, human approach to all of this. 

QUICK TURNS/ When It Comes to Policy Impact, Is NPV the MVP? 

Yesterday, we talked about a paper that shed light on how to think about “net present value” in the context of the IRA. Everyone on the finance side probably rolled their eyes at how obvious all of that was, but it’s clear that a better understanding of NPV is going to help uncover the impact of various policy changes.

If you want to go deeper, this is a great new piece from the Journal of Comparative Effectiveness Research that looks at the impact of market access decisions on NPV, concluding that kind of thinking will soon become standard: “Looking to the future, the integration of market access considerations into revenue forecasting and ultimately NPV calculations will become, if it is not already, of fundamental importance to all investors and drug developers.”

ELSEWHERE: 

• It sounds like the oral arguments in Boehringer Ingelheim IRA appeal didn’t go all that well, per Bloomberg Law’s take, but reading how judges are tilting is more art than science. 

• Lilly’s Dave Ricks is on the record around tariffs: "I think it's a pivot in US policy, and it feels like it'll be hard to come back from here … We have to eat the cost of the tariffs and make trade-offs within our own companies. Typically that will be in reduction of staff or research and development (R&D) and I predict R&D will come first. That's a disappointing outcome."

• Mehmet Oz is your new CMS administrator.

• It’s a little tangential to the usual focus of this newsletter, but if you’re on the manufacturer side of things, this Agency IQ piece about the short-term future of FDA user fees is a must-read. Yes, there are ways of fixing the problem if things turn catastrophic, but I don’t think anyone is all that jazzed about the prospect of a regulatory-legislative fire drill.

• The FTC lawsuit against PBMs is back on after the new FTC chair un-recused himself from the case. We’re living in extraordinary times. 

• The UK government is getting close to a fix for the unexpectedly large payments that industry is required to pay back to the government as a part of a drug-spending deal, according to the FT.

• How is the Medicare Prescription Payment Plan a/k/a “smoothing” a/k/a MPPP a/k/a M3P going? Not great, Bob!, says a new poll from the Partnership to Fight Chronic Disease. About half of all seniors haven’t even heard of it. (Which felt low to me.) The good news: Once you tell beneficiaries about the program, they end up being supportive of the concept. 

Cost Curve is produced by Reid Strategic, a consultancy that helps companies and organizations in life sciences communicate more clearly and more loudly about issues of value, access, and pricing. We offer a range of services, from strategic planning to tactical execution, designed to shatter the complexity that hampers constructive conversations. 

To learn more about how Reid Strategic can help you, email Brian Reid at [email protected].