Insights: Clients

340B Drug Discount Program

The Health Resources and Services Administration’s (HRSA) Office of Pharmacy Affairs (OPA) announced it has approved eight drugmakers for participation in the 340B Rebate Model Pilot Program. The model – which will start January 1, 2026, and run for at least a year – will allow drugmakers to provide 340B-discounted drug prices using a rebate...

Medicare Physician Fee Schedule (PFS) Reimbursement

CMS has issued the CY26 Physician Fee Schedule (PFS) final rule. Under the rule, CMS will implement two separate conversion factors (CFs). For Alternative Payment Model (APM) participants, the aggregate CF is set at $33.57, a 3.77% increase ($1.27) from the CY25 CF of $32.35. For non-qualifying participants (non-QPs), the aggregate proposed CF...

Drug Pricing (Medicaid/MFN)

CMS’s Center for Medicare & Medicaid Innovation (CMMI) has announced a new voluntary drug pricing model called GENEROUS (GENErating cost Reductions fOr U.S. Medicaid). Under the model, manufacturers will provide supplemental prescription drug rebates to participating states to align Medicaid net prices with what certain other countries pay (i.e.,...

Drug Pricing/Coverage (GLP-1s)

The White House has secured drug pricing commitments from Eli Lilly and Novo Nordisk. Like the commitments from other drugmakers (i.e., Pfizer, Merck), Lilly and Novo have agreed to guarantee most-favored nation (MFN) prices on all new medicines and provide state Medicaid programs access to MFN drug prices. However, the two companies have made...

Trade (IEEPA/Supreme Court Aftermath)

Assuming the Supreme Court bars the use of the International Emergency Economic Powers Act (IEEPA) to impose broad-based country-specific tariffs, questions arise around whether and how refunds will be available to the firms that have paid them this year (a total estimated at ~$90b at this point), as well as whether and how the administration will...

Trade (IEEPA/Supreme Court)

The Supreme Court heard oral arguments regarding President Trump’s imposition of tariffs under the International Emergency Economic Powers Act (IEEPA). Trump has used IEEPA to impose his sweeping “reciprocal” country-based tariffs. He used Sec. 301 to impose his first term tariffs on China and Sec. 232 to impose sector-based tariffs. Those...