Insights: Clients

Drug Pricing (Most Favored Nation, Tariffs)

During a White House event this week, Pfizer announced it would provide Most Favored Nation (MFN) pricing (matching the lowest prices in other developed countries) for its drugs in the Medicaid program (scope of products unspecified), apply MFN pricing on a go-forward basis on all “new innovative medicines” Pfizer brings to market (payer focus...

Tech / Media / Telecom

Export Controls/China/Semiconductors

The Commerce Department issued a rule that would add to its entity list (blacklist) any subsidiaries that are at least 50% owned by a company already on the entity list. Firms on the entity list are not allowed to contract with U.S. firms unless the Commerce Department grants the U.S. firm a license to do so. The entity list expansion is not...

Healthcare, Macro

Fiscal Year 2026 Funding/Government Shutdown, ACA

Yesterday’s meeting between President Trump and Congressional leaders yielded no progress towards resolution of FY26 government funding. In fact, both sides emerged from the meeting echoing their partisan messages with no indication they intend to soften their current positions (i.e., Democrats demanding that an extension of enhanced ACA...

Fed Personnel/Litigation

The various lawsuits challenging President Trump’s ability to fire members of independent boards are moving to a more advanced stage. Most notably, last week the Supreme Court (SCOTUS) agreed to take up the case of Rebecca Slaughter, a member of the Federal Trade Commission (FTC), whom Trump attempted to fire in March. Separately, Trump has filed...

Mergers & Acquisitions

The EC will soon decide whether to issue a formal statement of objections (SO) against the deal. An SO typically issues on or around the 40th business day of the EC’s review, which would be October 10th in this case. The M&A publication Dealreporter reported today that the case team reviewing the transaction has found no basis for an SO and has...

Drug Pricing/Most-Favored Nation Pricing (MFN)

HHS has submitted a Notice of Proposed Rulemaking (NPRM) entitled “Global Benchmark for Efficient Drug Pricing (GLOBE) Model” – presumably outlining a CMS Innovation Center (CMMI) model testing MFN pricing – to the White House’s Office of Information & Regulatory Affairs (OIRA) for review. This is the final step before a regulation is formally...