Why AFPs Are So Hard to Detect — and What Manufacturers Should Do Next

Part 4 of Our AFP Intelligence Series: The Hidden Threat to Specialty Brand Revenue & Patient Care

AFPs are difficult to detect by design. Building an effective response starts with making the
invisible visible.

This blog series has reported on how Alternate Funding Programs (AFPs) operate and the
hidden ways these programs reshape patient access, alter brand economics, and
introduce gaps between what is happening in the market and what is visible in commercial
data.

The remaining challenge is understanding how to respond. Even when brand teams
recognize inconsistencies—when revenue does not align with volume or when patient
engagement appears lower than expected—the underlying cause is often difficult to
isolate. AFP activity does not appear as a discrete signal. Rather, it is embedded within
otherwise familiar data, making it easy to misinterpret and difficult to act on.

To move forward, manufacturers must shift from recognizing the problem to building the
capability to see and manage it.

Where Visibility Breaks Down

AFP activity does not sit within a single dataset or system. It unfolds across the access
pathway, appearing partially in multiple places without being fully captured in any one
view.

Patients may be visible in dispensing data while absent from commercial claims. They may
be enrolled in assistance programs without entering manufacturer hubs. They may be
actively receiving therapy while remaining disconnected from the intended support
infrastructure.

Individually, these signals are not unusual. Together, they indicate a different pathway—but
one that requires deliberate analysis to identify.

This is where visibility breaks down. What appears to be normal variation in the data may, in
fact, reflect a structural shift in how patients access therapy.

The Limits of Existing Approaches

Most commercial analytics frameworks were built to measure performance within a stable
system of coverage and reimbursement. They are designed to track volume, adherence,
and financial outcomes, assuming the underlying access pathway remains consistent.

AFPs disrupt that assumption. Rather than removing patients from the system, AFPs
change how those patients move through it. Because those changes span multiple
stakeholders and systems—PBMs, specialty pharmacies, Patient Assistance Programs
(PAPs), and foundations—no single dataset captures the full sequence of events.

Without integrating these perspectives, AFP activity remains embedded within standard
reporting, often attributed to data discrepancies rather than recognized as a distinct
pattern.

Understanding where visibility breaks down is only part of the challenge. The more
important question is how manufacturers can reestablish that visibility in a system that
was not designed to provide it.

Rebuilding Visibility: What an AFP-Aware Strategy Looks Like

Building an effective response to AFP activity requires more than incremental adjustments.
It takes a coordinated approach that aligns analytics, program design, and stakeholder
engagement around a more complete understanding of the access landscape.

A foundational step is investing in AFP-specific analytics and data infrastructure, where
manufacturers move beyond siloed reporting and begin cross-referencing specialty
pharmacy dispensing data with commercial claims, PAP enrollment records, and hub
intake data. This type of integrated analysis makes it possible to identify patterns that
would otherwise remain hidden—particularly when patients appear in some systems but
not others.

At the same time, PAPs must evolve to reflect the realities of AFP activity. Programs
originally designed for uninsured or underinsured populations should incorporate
verification processes that can identify potential AFP referral pathways, including
confirmation of insurance status and visibility into benefit design. When implemented
thoughtfully, these measures can reduce inappropriate utilization without limiting access
for patients who genuinely need support.

Strengthening hub programs and patient engagement models is another critical
component. AFP workflows are often successful because they can redirect patients away
from manufacturer-preferred channels without patients fully understanding the
implications. Hub programs that provide consistent, proactive support—through clinical
outreach, adherence management, and patient-reported insights—create a more stable
and continuous access experience that is less susceptible to disruption.

Beyond internal capabilities, manufacturers also benefit from more proactive engagement
with employers and payer stakeholders, particularly those who may not fully understand
the downstream implications for the patient experience of AFP program design. Sharing
data on treatment delays, adherence disruptions, and overall outcomes can help inform
more balanced decision-making at the benefit-design level.

Finally, monitoring regulatory and legal developments is becoming increasingly important
as scrutiny of AFP-related practices continues to evolve. Changes in policy or enforcement
may alter the operating environment, creating both risks and opportunities for
manufacturers seeking to manage AFP exposure.

No single action will fully address the impact of AFPs. However, a coordinated strategy that
improves visibility, strengthens access pathways, and aligns stakeholders can significantly
reduce both financial and patient-related risk.

Seeing the Invisible

AFPs represent one of the most consequential and least visible challenges in specialty
pharmaceutical market access today. Their evolution from manual, opportunistic cost-
shifting strategies into highly coordinated patient diversion systems has outpaced the
industry’s ability to detect, quantify, and respond to their impact.

As a result, many brand teams are managing performance against a financial reality that
their data does not fully capture, while patients navigate access journeys that are more
complex and fragmented than intended.

Addressing this challenge requires a clear-eyed understanding of its scale. AFP activity is
not a marginal issue. For many specialty brands, it represents a meaningful source of
gross-to-net erosion and patient experience disruption that exists largely outside the field
of view of traditional analytics.

Bringing that activity into view requires investment in detection infrastructure, thoughtful
reform of PAPs, and deeper engagement with the stakeholders who shape access
pathways.

The organizations that build these capabilities now will be better positioned to protect both
their commercial performance and the continuity of care for the patients they serve.

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