MDRP 2025 Wrap-up
This week, the pharma industry and partners — manufacturers, government agency representatives, health care policy lawyers, state rebate representatives, consultants and vendors — gathered in an unseasonably warm Chicago at the annual Medicaid Drug Rebate Program Summit (MDRP).
As many speakers noted, the days when MDRP had little “new” to discuss are long gone — and it was certainly not the case this year!
Salient topics
- Implementation of the Inflation Reduction Act (IRA) including new rebate requirements and the effectuation of the Maximum Fair Price (MFP) for selected drugs for initial price applicability year (IPAY) 2026;
- Recently announced 340B rebate pilot program;
- Calendar Year 2026 Medicare Physician Fee Schedule (PFS) Proposed Rules;
- State Price Transparency Reporting (SPTR) updates;
- Most Favored Nation (MFN) pricing;
- Potential tariffs; and
- Expansion of the 340B program.
High-level takeaways
There was a time when a Government Pricing (GP) team may have been an important but secondary contributor to a pharmaceutical manufacturer’s business strategy. Nowadays, GP teams are an increasingly crucial part of operations and compliance, as the government continues to expand requirements and implement new programs. Couple this expansion with the current administration’s focus on drug pricing, and it is critical to be watching closely for new developments, and to have contingency plans in place.
Information-sharing and best-practice exchange among manufacturers proved invaluable, particularly as new programs are being implemented quickly. Still, many questions remain, such as:
- Is the healthcare system operationally ready to effectuate the MFPs for selected drugs for IPAY 2026?
- Will CMS finalize and/or delay the proposals for Reasonable Assumptions and Fair Market Value assessments outlined in the CY 2026 PFS?
- How will potential tariffs affect pricing and supply chains?
- Will the administration succeed in reviving Most Favored Nation pricing?
- How might CMS’s FMV/BFSF assessment proposals affect Medicaid’s AMP?
Dates to watch
- 10/1 - How will the Trump administration respond to the 17 large manufacturers who received MFN pricing letters?
- 10/15 - Deadline for HRSA to review/approve manufacturer rebate proposals (limited to 10 drugs selected for MFP/IPAY 2026)
- 11/1 - Expected release for Physician Fee Schedule Final Rules
- Ongoing - tariffs (developments expected in weeks, not months)
With these milestones — plus the kickoff of VA’s Public Law season and Q3 close — GP teams will be busier than ever. Please reach out if you’d like to further discuss how these changes may impact your business.
Published on Sept. 18, 2025 by Jenny Bulkin