Integrating Price Benchmarks and Comparative Clinical Effectiveness to Predict Initial Price Offers for Medicare Drug Price Negotiation (Initial Price Applicability Year 2027)

Abstract

Objectives

This study estimated initial price offers for the 15 drugs selected for the Medicare Drug Price Negotiation Program in the Initial Price Applicability Year 2027.

Methods

We applied the Centers for Medicare and Medicaid Services guidance to construct a list of therapeutic alternatives for each drug. Price benchmarks included the statutory discount, Big 4/Federal Supply Schedule prices, estimated Medicare Part D net prices, and wholesale acquisition cost. Comparative effectiveness evidence was extracted from peer-reviewed network meta-analyses, clinical guidelines, and Institute for Clinical and Economic Review assessments. Drugs were rated on a 4-tier scale (A-D) based on comparative net health benefit. Initial offers were then estimated by applying market-based discounts depending on the availability and type (branded vs generic) of therapeutic alternatives.

Results

For 6 drugs, statutory or Big 4/Federal Supply Schedule prices anchored the estimated initial offers. Four drugs were informed by clinically comparable branded alternatives, leading to approximately 20% reductions from net price. Two drugs with primarily generic alternatives received larger discounts of approximately 30%. Three drugs with therapeutic alternatives previously negotiated in Initial Price Applicability Year 2026 were assigned either the established maximum fair price or a market-based premium (semaglutide). Across all 15 drugs, estimated discounts ranged from 32% to 78% off list price and 16% to 56% off net price.

Conclusions

Our analysis highlights how Centers for Medicare and Medicaid Services may incorporate statutory discounts, prior maximum fair prices, and comparative effectiveness evidence into initial price offers, although uncertainty remains. An explicit health technology assessment framework could strengthen future negotiation cycles unless international price referencing policy intercedes.

Authors

Kevin H. Li Emma M. Cousin Nico Gabriel Sean D. Sullivan

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