The Honorable Kathy Hochul
Governor of New York
New York State Capitol Building
Albany, NY 12224
Dear Governor Hochul,
On behalf of the Pharmaceutical Industry Labor-Management Association (PILMA), I write to
express strong opposition to the inclusion of 340B expansion language in the final New York
State budget, including the language reflected in A.6222 (Paulin) / S.1913 (Rivera) and Part W
of S.9007B.
PILMA is a shared coalition of labor unions and biopharmaceutical industry employers united by
a commitment to growing the economy, creating high-quality union jobs, fostering medical
innovation, and supporting access to affordable, high-quality healthcare for working families.
Our members are deeply invested in policies that promote fairness, transparency, and long-term
sustainability across the healthcare system.
As a partnership backed by labor, PILMA brings a direct worker perspective to policies that
affect union-sponsored health plans, wages, and benefits. The concerns outlined in this letter
reflect those shared by labor organizations within our coalition.
While we share concerns about prescription drug affordability, this proposal represents an
unnecessary and problematic state-level intervention into the federal 340B Drug Pricing
Program. Legislation of this kind reinforces a system that continues to lack sufficient
transparency and accountability.
Just as importantly, these provisions do not ensure that 340B savings are reaching patients or
being used to lower healthcare costs. Instead, they risk reinforcing inefficient distribution models
while shifting additional costs onto employers and jointly administered Taft-Hartley health plans
that are not eligible for 340B discounts. Unchecked use of 340B has increased prescription drug
spending for Taft-Hartley plans by more than four percent per claim, costing union-sponsored
health plans billions of dollars annually. Workers and retirees ultimately bear those costs through
higher premiums.
These concerns are consistent with broader concerns across the labor community that 340B
abuse and expansion can undermine the affordability of coverage for working families and erode
the value of collectively bargained health benefits. New York should not entrench these
problems through the state budget.
Any meaningful reform of the 340B program should occur at the federal level, where Congress
can establish clear, uniform standards for transparency, accountability, and patient benefit. Apatchwork of state-by-state mandates will only deepen existing problems, increase administrative
complexity, and drive up costs for workers, retirees, and employers.
For these reasons, PILMA respectfully urges that the 340B language reflected in A.6222 /
S.1913 and Part W of S.9007B not be included in the final enacted New York State budget.
Sincerely,
AJ Stokes
Executive Director
Pharmaceutical Industry Labor-Management Association (PILMA)