Colorado’s March 2025 Amended SIP Application

The state of Colorado submitted its newest revised application to operate a state importation program in March. With each successive application, the state has been seeking to import fewer drugs and projecting less potential savings.

The state’s first application listed 112 unique drugs and dosages for prospective importation. Three amended applications later, that number has dropped to 20 unique drugs and dosages, two fewer drugs than in the previous amended application. The newest proposal dropped Ibrance, a breast cancer medication, and Spiriva Respimat, an inhaler used to treat asthma and chronic obstructive pulmonary disease. 

While we can only speculate why these two drugs were removed from the state’s list, the fact that Spiriva Respimat inhalers are now on the manufacturer’s $35 inhaler list could be why the state is no longer seeking to import them. In its 2024 cost savings analysis, the state said that each dose of imported Spiriva Respimat would cost $20.51. Each inhaler contains 30 doses, bringing the total for the inhaler to $615.30, far above the $35 cap available to most individuals with commercial insurance or no insurance in the U.S.

What the state of Colorado has spent nearly six years after SB19-005 was signed into law is anyone’s guess, but those costs continue to chip away at any future savings, should they ever materialize. In its initial submission, the state hypothesized that it could save $53 - 88M annually importing medicines from Canada. The most recent cost analysis estimated that the state would save $46.2M during the first three years operating its SIP. That works out to just over $15M a year. 

Logistically, Colorado has made no forward progress in resolving the major program impediments, including those listed in the annual report in 2023 versus 2024.

• Canadian patients, pharmacists, and doctors are experiencing major shortages and are not willing to hand over their drug supply to the U.S., a country with nine times Canada’s population.
• Canadian wholesalers continue to be barred by their own regulator, Health Canada, from exporting drugs to the U.S.
• Drug manufacturers in Canada do not want to participate in the program for fear of being unable to meet the needs of Canadian patients, their first priority.

Florida is the only state that has received approval by the FDA for its drug importation program, but despite spending over $60M, it has yet to import a single pill. Why is Colorado continuing to follow in the footsteps of Florida’s folly?

Colorado legislators need to realize that drug importation is not providing the savings they thought it would. Instead, they should examine what has actually worked in other states to lower the cost of prescription drugs. For example, West Virginia created a carve out for prescription drug services for its Medicaid program that saved the state $54M in one year. In 2021, Kentucky started using a single pharmacy benefits manager and a single preferred drug list for its Medicaid program, saving the state $282M in less than two years. 

There are policies and programs that states can implement to lower the cost of prescription drugs. Canadian drug importation just isn’t one of them.

Below are all of the documents that are part of Colorado’s March 2025 amended SIP application:

• Amended SIP Application
• Amended Appendices List
• Appendix A- SIP Sponsor 
• Appendix B- Foreign Seller
• Appendix C- Importer
• Appendix D- Required Data Elements 
• Appendix E- Actuarial Cost Analysis 
• Appendix F- Certification Reports 
• Appendix G- Figure Library 
• Appendix H- FDA Correspondence 
• Appendix I- Stakeholder Engagement

Previous applications can be found on Colorado’s drug importation program page.