Healthcare & Life Sciences: Drug Pricing Digest — Number 67

Inflation Reduction Act, Healthcare Reform, and General Developments 

TRUMP CONTINUES TO URGE CONGRESS TO CODIFY MFN POLICY

The Trump health policy framework, which we discussed in issue No. 64 of this digest, calls on Congress to codify the most favored nation (MFN) deals that manufacturers have entered into with the government. President Trump reiterated this request in the State of the Union address on February 24, 2026, and administration officials are continuing to discuss the issue.

Sources: InsideHealthPolicy (first, second, third), PoliticoPro (first, second), Scrip, 340B Report.

Check out Latham’s recent podcast that discusses new healthcare transaction review laws that more than 10 states adopted or proposed in 2025, and how the increased level of oversight affects companies and investors in the industry.

COMPANIES DISCLOSE MFN DETAILS IN ANNUAL REPORTS

Some of the 16 companies that have entered into MFN deals with the Trump administration have disclosed certain features of the deals in their annual reports recently filed with the Securities and Exchange Commission. 

Source: StatNews.

CMS EXTENDS GENEROUS APPLICATION DEADLINE

The Centers for Medicare & Medicaid Services (CMS) extended the application period for the voluntary Generous payment model — which focuses on Medicaid — by a month, from March 31 to April 30, 2026. The change was noted on the CMS Generous website and reflected in the manufacturer Request for Applications.

Sources: Pink Sheet, InsideHealthPolicy, StatNews, Reuters.

STAKEHOLDERS CONTINUE TO DISCUSS GLOBE AND GUARD PAYMENT MODELS, MFN IMPLICATIONS

The comment period for the Globe and Guard mandatory Medicare payment models, which we discussed in issue No. 62 of this digest, ended on February 23, 2026. Stakeholders are discussing the comments and the broader implications of the MFN policy.

Sources: BloombergLaw, InsideHealthPolicy (first, second, third), StatNews (first, second), Scrip (first, second), Pink Sheet (first, second), 340B Report.

Democratic lawmakers continue to seek more information about the MFN deals and policy.

Source: InsideHealthPolicy (first, second).

STAKEHOLDERS CONTINUE TO DISCUSS TRUMPRX IMPLICATIONS

Following the release of the TrumpRx website, which we discussed in issue No. 65 of this digest, stakeholders continue to discuss implications of the direct-to-consumer distribution model.

Sources: BloombergLaw (first, second), StatNews.

MEDICARE MAXIMUM FAIR PRICE IMPLEMENTATION

The Maximum Fair Prices (MFPs) for the first set of drugs that were subject to forced negotiations under the Inflation Reduction Act (IRA) became effective on January 1, 2026. Pharmacies are raising concerns regarding how the MFPs are being implemented. 

Sources: InsideHealthPolicy, BloombergLaw.

Medicaid Drug Rebate Program (MDRP)

No developments to report.

340B Program

MANUFACTURER CLAIMS DATA REQUIREMENT FOR IN-HOUSE PHARMACY DISPENSES

As we discussed in issue No. 64 of this digest, as of February 1, 2026, a major pharmaceutical manufacturer is requiring covered entities to submit claims-level data for all their 340B dispenses, including dispenses from in-house pharmacies. Another manufacturer has now imposed a similar requirement.

Sources: InsideHealthPolicy, 340B Report (first, second).

HRSA EXTENDS REBATE MODEL RFI DEADLINE

The Health Resources & Services Administration (HRSA) extended the Request for Information (RFI) comment deadline regarding the 340B Rebate Model Pilot Program from March 19 to April 20, 2026. 

Sources: InsideHealthPolicy, 340B Report.

LITIGATION REGARDING CHILD SITE REGISTRATION REQUIREMENTS CONTINUES

In response to the COVID-19 pandemic, HRSA had waived certain registration requirements for covered entity child sites and then withdrew the waiver in 2023, as discussed in issue No. 65 of this digest. Litigation brought by covered entities challenging that withdrawal remains ongoing, with the US District Court for the District of Columbia ruling against HRSA.

Sources: BloombergLaw, Law360, 340B Report.

HRSA ISSUES FURTHER ADR DECISION

On February 27, 2026, HRSA updated its Administrative Dispute Resolution (ADR) website with the summary of a new ADR decision, bringing the total number of decisions issued under the revised ADR process to five.

We discussed the prior ADR decisions in issues No. 47 and No. 64 of this digest.

Source: 340B Report.

ADDITIONAL STATES ADOPT CONTRACT PHARMACY LAWS

More states have enacted or proposed legislation that would bar drug manufacturers from restricting contract pharmacy access. Some bills would require covered entities to make disclosures regarding 340B discounts. We note that legislative action related to the 340B program may have occurred in other states but has not yet been reported in the trade press. 

Source: 340B Report (first, second, third, fourth).

MANUFACTURER CHALLENGES TO STATE 340B LAWS CONTINUE

Drug manufacturer litigation challenging the 340B laws enacted by various states continues. 

Sources: BloombergLaw (first, second, third, fourth), Law360 (first, second, third), StatNews, 340B Report (first, second, third, fourth, fifth).

Medicare Part B 

No developments to report. 

Medicare Part D

No developments to report. 

State Law Developments  

CHALLENGE AGAINST OREGON PRICE TRANSPARENCY LAW CONTINUES

Manufacturer litigation continues against the Oregon state law that established the Oregon Prescription Drug Price Transparency Program, which we discussed in issue No. 22 of this digest. 

Sources: BloombergLaw, Law360.