AVERAGE SALES PRICE AS A FAIRER BENCHMARK FOR MOST-FAVORED-NATION DRUG PRICING: A US-CANADA-GERMANY SPECIALTY-DRUG BASKET ANALYSIS
Author(s)
Saurabh Aggarwal, BS, MS, PhD1, Sushil Kumar, BS2, Ozlem Topaloglu, PhD, MPH3.
1NOVEL Health Strategies, Chevy Chase, MD, USA, 2Institute for Global Policy Research, Washington, DC, USA, 3NOVEL Health Strategies, Bethesda, MD, USA.
1NOVEL Health Strategies, Chevy Chase, MD, USA, 2Institute for Global Policy Research, Washington, DC, USA, 3NOVEL Health Strategies, Bethesda, MD, USA.
OBJECTIVES: International price comparisons underpin Most-Favored-Nation (MFN) pricing proposals, yet most rely on US list prices (Wholesale Acquisition Cost), which overstate realized US prices because of large confidential rebates. We used Medicare Part B Average Sales Price (ASP) , a net transaction-based measure, as a more realistic US benchmark to compare selected high-cost specialty drugs against Canada and Germany.
METHODS: From the 2026 CMS Part B ASP file we selected high-cost specialty drugs and matched each to formulation and unit. US price = payment limit (ASP+6%) scaled to dose/course. Comparator prices were official government list prices: Germany from G-BA assessments/Lauer-Taxe; Canada from PMPRB Meds Entry Watch. Using same-drug baskets (a drug included only if priced in both countries), we computed aggregate ratios (Σforeign/ΣUS) and mean/median per-drug discounts, converted to USD.
RESULTS: Against US ASP, German list prices were a mean 44% lower (median 48%) across 7 drugs (six CAR-T therapies plus vutrisiran); Canadian list prices were a mean 30% lower (median 31%) across 5 CAR-T therapies. Per-drug differences varied widely (−58% to +4%): CAR-T discounts ranged 43-58% (Germany) and 21-39% (Canada), whereas vutrisiran's German list price exceeded US ASP by 4%.
CONCLUSIONS: Even using a conservative net US benchmark (ASP), international list prices were materially lower for most drugs, a median 48% (Germany) and 31% (Canada) below US ASP. However, comparators are list prices; realized foreign prices after confidential rebates (German Erstattungsbetrag, Canadian pCPA agreements) are lower still, so findings represent an upper bound. ASP-based benchmarking offers fairer US comparison than list price, but net-to-net international data and a larger sample remain essential for MFN-relevant analysis.
METHODS: From the 2026 CMS Part B ASP file we selected high-cost specialty drugs and matched each to formulation and unit. US price = payment limit (ASP+6%) scaled to dose/course. Comparator prices were official government list prices: Germany from G-BA assessments/Lauer-Taxe; Canada from PMPRB Meds Entry Watch. Using same-drug baskets (a drug included only if priced in both countries), we computed aggregate ratios (Σforeign/ΣUS) and mean/median per-drug discounts, converted to USD.
RESULTS: Against US ASP, German list prices were a mean 44% lower (median 48%) across 7 drugs (six CAR-T therapies plus vutrisiran); Canadian list prices were a mean 30% lower (median 31%) across 5 CAR-T therapies. Per-drug differences varied widely (−58% to +4%): CAR-T discounts ranged 43-58% (Germany) and 21-39% (Canada), whereas vutrisiran's German list price exceeded US ASP by 4%.
CONCLUSIONS: Even using a conservative net US benchmark (ASP), international list prices were materially lower for most drugs, a median 48% (Germany) and 31% (Canada) below US ASP. However, comparators are list prices; realized foreign prices after confidential rebates (German Erstattungsbetrag, Canadian pCPA agreements) are lower still, so findings represent an upper bound. ASP-based benchmarking offers fairer US comparison than list price, but net-to-net international data and a larger sample remain essential for MFN-relevant analysis.
Conference/Value in Health Info
2026-11, ISPOR Europe 2026, Vienna, Austria
Value in Health, Volume 29, Issue 12S
Code
HPR12
Topic
Epidemiology & Public Health, Health Policy & Regulatory, Health Technology Assessment
Topic Subcategory
Reimbursement & Access Policy