By forcing disclosure of the lowest net price, MFN could dismantle the system of confidential rebates. This is a problem for payers (health plans, PBMs) who use their ability to negotiate superior, secret rebates as a key competitive advantage. A transparent system creates a level playing field, eroding this value proposition.
Agreements often labeled "MFN deals" are more accurately tariff-avoidance arrangements. In these deals, pharmaceutical companies commit to significant investment in US manufacturing in exchange for price parity, suggesting a broader policy goal beyond just drug price reduction and focused on boosting the domestic economy.
The Most Favored Nation (MFN) policy was strategically designed to be disruptive. The aim was less about implementing a specific pricing framework and more about forcing the pharmaceutical industry to change its behavior, re-evaluate global strategies, and engage in new types of negotiations, which has already proven effective.
Despite promises of affordability, MFN's price reductions primarily lower costs for the US government. For the majority of patients on fixed copay plans, their out-of-pocket expenses for a drug will not decrease even if the government negotiates a lower price. Only patients on coinsurance plans would see a direct reduction.
The unpredictable nature of the Most Favored Nation (MFN) policy makes fixed launch plans obsolete. Companies must now create multiple, dynamic launch sequences tied to specific policy "signposts." This requires a shift towards continuous scenario planning and risk mitigation to remain prepared for various potential outcomes.
While MFN may encourage value-based deals globally, it creates an implementation hurdle. MFN policies reference a simple price per unit (SKU), but value-based agreements are outcome-dependent. This makes calculating and reporting a single, compliant "net price" to the US government incredibly complex and operationally burdensome.
The Most Favored Nation (MFN) policy forces a difficult choice: launch early in Europe and risk a lower US reference price, or delay the European launch to protect US revenue, slowing patient access. This dilemma upends traditional global launch strategies, creating commercial, ethical, and operational problems for pharma companies.
MFN's pressure on global pricing will change how innovation is valued. Truly disruptive drugs may command higher prices ex-US, while incremental "me-too" drugs in crowded classes will not. This will force pharma companies to shift R&D investment away from iterative improvements and toward therapies with radical treatment-disrupting potential.