News|Articles|March 4, 2026 (Updated: April 8, 2026)

MHE Publication

  • MHE April 2026
  • Volume 36
  • Issue 4

The Great Healthcare Plan, MFN drug prices and the political implications of the end of ACA enhanced subsidies: Here are 7 takeaways from the MHE-AJMC webinar

Fact checked by: Yasmeen Qahwash
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Key Takeaways

  • Executive-branch levers include FTC actions targeting PBM conduct and intensified hospital price-transparency enforcement, while flagship proposals like consumer accounts and PBM reform require congressional action.
  • Voluntary MFN commitments by 16 manufacturers reportedly cover ~70% of Medicare drug spending, potentially obviating GUARD/GLOBE finalization while avoiding predictable legal challenges.
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Lindsay Greenleaf, J.D., MBA, and Nicolas Ferreyros offered insight and analysis during a March 3 webinar about healthcare policy and politics.

Managed Healthcare Executive (MHE) and The American Journal of Managed Care (AJMC) held a webinar March 3 on Trump administration healthcare policies and politics. Panelists Lindsay Greenleaf, J.D., MBA, head of policy, research and analysis for ADVI Health and member of the MHE editorial board, and Nicolas Ferreyros, managing director of policy, advocacy and communications for the Community Oncology Alliance, shared insights on President Donald Trump’s Great Healthcare Plan, most-favored-nation (MFN) drug pricing, Medicare drug price negotiation and other topics. The webinar was moderated by Maggie L. Shaw, a lead editor at AJMC, and Peter Wehrwein, managing editor of MHE.

You can watch the webinar here.

Here are some of the points made — and opinions shared — by Greenleaf and Ferreyros during the hourlong webinar.

Drugmakers have entered into voluntary agreements. Maybe the GLOBE and GUARD models don’t need to be finalized?

Greenleaf noted that some key elements of the Great Healthcare Plan would require legislation and congressional approval, such as the signature proposal to create accounts like the health savings accounts many people have through employer-based insurance, as well as further pharmacy benefit manager (PBM) reform. But that leaves plenty of room for executive action that doesn’t require congressional involvement. Greenleaf noted, for example, the possibility of Federal Trade Commission (FTC) settlements with CVS Caremark and Optum on the heels of the FTC settlement with Express Scripts that was announced on Feb. 4. She said the administration could also step up enforcement of existing hospital price transparency rules.

As part of its MFN drug pricing policies, the administration has proposed using demonstration projects, or “models,” authorized by the Center for Medicare and Medicaid Innovation, also known as the CMS Innovation Center, Greenleaf explained. The GUARD and GLOBE models that the administration proposed in December 2025 would require rebates from drugmakers so that prices paid in the Medicare Part D (the GUARD model) and Part B (the GLOBE model) programs are at the same level as MFN prices paid in other countries. But Greenleaf said 16 pharmaceutical companies have already voluntarily agreed to MFN pricing and that, according to analysis done by ADVI, which has drugmakers as clients, products marketed by the companies that volunteered account for 70% of Medicare drug spending.

“Why finalize these models, really?” Greenleaf said. “If you think about it, at this stage, [the administration] used the threat of these models coming out as a way to get manufacturers to the table voluntarily, and they succeeded. The president sent out letters to those CEOs. You have 16 companies now that have voluntarily agreed to MFN pricing across all of Medicaid and for all future drug launches. That is huge. That is a huge victory for the president. He should be taking that victory lap.”

Greenleaf said if the GUARD and GLOBE models are finalized, it is a certainty that they will be challenged in court. “I just hope they don’t even go there,” she said.

Republicans may pay a political price for the end of enhanced ACA premiums subsidies, but…

Greenleaf and Ferreyros agreed that enhanced Affordable Care Act (ACA) subsidies may factor into the outcome of the midterm elections in November that will determine whether the Republicans keep their comfortable majority in the Senate and hang on to the slender one in the House. Ferreyros noted that health insurance premiums are a pocketbook issue and that the expense affects people who don’t use the healthcare system. The end of the enhanced subsidies is driving the cost of ACA plans to an “unsustainable level,” he said, adding that “if you’re a patient with cancer or if you are a caregiver to someone with cancer, it is extremely unaffordable. And shifting toward a catastrophic plan is not a helpful solution in those scenarios; they don’t cover enough, clearly.”

However, Ferreyros also said that there has been continual growth in insurance company profits since passage of the ACA. “The UnitedHealthcares of the world continue to grow and grow,” he said, adding that “we are not in a sustainable place” and “we need to come to the table to figure it out.”

“There very well may be a political cost to this,” Greenleaf said, in reference to the end of the enhanced subsidies, adding, “and that’s unfortunate.” Greenleaf said continuing the subsidies would have had a 10-year price tag of $350 billion. She also mentioned the need for more oversight and ending fraud and abuse in the ACA exchanges. “There’s a lot we need to do to clean up the exchanges,” Greenleaf said. “It’s way too expensive. Republicans just didn’t want to continue with business as usual.”

Figuring out drug prices paid in other countries for MFN purposes is difficult/impossible — and there is the QALY problem

Ferreyros noted that prices paid in other countries are subject to “secret rebates and discounts that are offered, so list price, net price … are very hard things to define” for MFN purposes. He also noted that an MFN price may be impossible to identify if a drug is launched only in the U.S. and that U.S.-only launches may be a consequence of the administration’s policies.

Another complication, in Ferreyros’ view, is that prices paid in other countries, particularly in Europe, are set by health technology assessments that use quality-adjusted life years (QALYs) and that kind of cost-effectiveness analysis have been explicitly rejected in the U.S. “You remember the concept of death panels during the Affordable Care Act debate,” he said.

Once hands-off, Republicans are now very much hands-on when it comes to drug pricing

Ferreyros said the Democrats used to lay claim to being the party that favored an activist role for government in drug pricing, with the prime example being the Inflation Reduction Act (IRA) of 2022 empowering CMS to negotiate Medicare drug prices for the first time. Government intrusion into pricing used to be anathema to Republicans and their free-market views, he noted, but that has changed with the Trump administration and its MFN drug pricing policy.

Direct-to-consumer market is a win for the administration — and an indictment of PBMs

Greenleaf said TrumpRx and the direct-to-consumer drug prices advertised there are examples of “taking a win, where even if it’s a small subset of drugs, do it. You are helping a lot of people by doing that.” She noted the limitations, noting that direct-to-consumer marketing is not going to be helpful when it comes to expensive drugs like those prescribed by oncologists.

Greenleaf also brought PBMs into this part of the discussion. “What the TrumpRx and direct-to-patient models are really showing is the flaws with the PBM model and the ways that insurance has not been working out for a lot of people and a lot of drugs.”

Ferreyros said PBMs have a role, “but they’ve overplayed their hand.” He continued, “The challenge is now reining them in so they serve more of the function that they originally needed to serve. And … if they stopped all this funny business with offshore [group purchasing organizations] and what sounds like money laundering and other things, maybe we can get back to this kumbaya world, where they serve their original intent and their original purpose. But the fact of the matter is, over the past two decades, it has mutated far beyond it.”

MFPs for Part B drugs are a “looming disaster” for oncologists, other specialists

Maximum fair prices (MFPs) are negotiated by CMS under the IRA. So far, CMS has negotiated — critics say “set” — for 25 drug covered by Medicare Part D. Starting in 2028, MFPs will also be applied to some Part B drugs, which are administered by physicians. As Ferreyros explained, oncologists and other physicians — typically specialists — are reimbursed for the drugs they self-administer to patients covered by Medicare Part B at the average sales price (ASP) of the drug plus 6% of that price. In simplified terms, the ASP is the weighted average of prices paid to manufacturers for Part B drugs. MFPs for Part B drugs are expected to be much less than the ASP prices, so the 6% that oncologists and other specialists collect will be much less. “We've done a calculation that it'll be about a 49% decrease in physician add-on payment — $12 billion a year in oncology alone,” Ferreyros said. “To quote one of my board members, that is a practice ending. That means these practices will no longer be economically operated for care to patients. And make no mistake about it, when a community oncology practice closes, the hospitals cannot just pick up the slack.”

The Community Oncology Alliance is backing the Protecting Patient Access to Cancer and Complex Therapies Act, a bill that would, in broad terms, keep Medicare Part B reimbursement rates to physicians at ASP plus 6% and require manufacturers to fund the difference between the ASP and MFP through rebates to the federal government. Last year, Milliman estimated that if the legislation were enacted, it would save patients and Medicare money but cost manufacturers $58.9 billion over a 10-year period.

Ferreyros described oncologists as the “canary in the coal mine” as the specialists most affected by MFPs, but other specialists will also be affected. “It is a looming disaster for practices. It’s not just oncology; it is rheumatology, neurology and several others.”

Drugmakers will continue to talk about the threat to innovation

Several analyses have shown that CMS price negotiation is likely to reduce Medicare expenditures. The IRA also put a new $2,000 cap on Part D out-of-pocket costs. On the other hand, pharmaceutical companies have said the stifling of drug discovery and development is the price that will be paid. Greenleaf said drug companies are “doing everything they can to make sure that it's not realized. But you need to talk about it now and raise alarm as early and loudly as possible.”

“We're on the cusp of some really incredible cures on the cancer front — Alzheimer's, rare diseases, etcetera,” Greenleaf said. “I do think that innovation threat is real. I think you're going to continue hearing manufacturers talk about it over and over again, especially as you have the IRA … MFN threats on top of that, and you have this explosive 340B-required drug discount program.”

The 340B Drug Pricing Program effectively requires drug manufacturers to sell their products to some hospitals and other providers at discounted prices. It has been a bone of contention. The hospitals that benefit say the program is essential to their economic well-being and helps cover the cost of the under- and uninsured patient population. Drugmakers say hospitals and other providers are abusing the program and using the money it generates for their own purposes.


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