Mapping the United States pricing and reimbursement journey
A complex, multi-faceted landscape
From a Medicare perspective, companies face a dichotomous structure of Medicare Fee for Service (FFS) – sometimes referred to as “traditional Medicare,” which fragments healthcare coverage, payment, and reimbursement by site of care – vs Medicare Advantage, which operates under Medicare guidelines but is managed by commercial companies.
Part D products, which are generally self-administered, are paid based on the list price and contracted rates with pharmacies without rebates included.4 Of note, the Inflation Reduction Act introduced Medicare-manufacturer price negotiation for the top utilized Medicare products under Part B and Part D.
Medicaid is administered by the states, with each state setting its own fee schedule, which, in our experience, is typically 30% to 40% lower than Medicare. There is a mandatory rebate for Medicaid, and there are often supplemental rebates, which are not incorporated into the reimbursement price.5
The commercial landscape spans a diverse network of plans, where reimbursement is based on list prices, along with contracted rates with healthcare professionals and pharmacies. This complex environment requires a nuanced understanding of changing dynamics, such as major PBM reforms6 that will reshape the compensation structure and the vertical integration of PBMs, specialty pharmacies, and retail pharmacies.7
Unravelling the market challenges
For non-U.S. biopharmaceutical companies, navigating the complex payer dynamic can be overwhelming.
Many manufacturers that are unaccustomed to the U.S. market may not understand that the price of the product is separate from the reimbursement that pharmacies, healthcare providers, and hospitals receive. That amount will depend on the payers, the contracts in place, or the overall payment system. With more than 1,000 commercial payers,8 and each with potentially different ways of covering the product and managing access, the landscape is further complicated and increasingly heterogeneous.
The patient support component is another factor non-U.S. companies may overlook. Even when drugs are covered by the payers, patients face out-of-pocket costs that have been increasing over time.9 Having patient support programs, including copay assistance programs, can improve access for patients who otherwise may not be able to afford the therapy, particularly when it comes to many newer, costly treatments, such as cell and gene therapies.
Global companies must also navigate a rapidly shifting geopolitical landscape, with tariffs and Most-Favored-Nation (MFN) pricing initiatives creating further P&R uncertainties. Companies will need to stay on top of a variety of current and emerging programs that could further weigh on P&R, including:
- The GENEROUS (GENErating cost Reductions fOr U.S. Medicaid) model, which uses manufacturer-reported average prices from 8 economically comparable countries, will impact Medicaid products.10
- GLOBE (Global Benchmark for Efficient Drug Pricing), which is a proposed mandatory model for certain Medicare Part B drugs.11
- GUARD (Guarding U.S. Medicare Against Rising Drug Costs) (GUARD), which will need to be factored in for certain Medicare Part D drugs.12
Frequent P&R missteps from non-U.S. manufacturers
An over-reliance on the list price vs net price after discounts and rebates is a common misunderstanding among non-U.S. manufacturers. There can also often be uncertainty about how best to price a therapy, for example, whether to price a product low to increase access or price it higher and offer rebates.
There is also a tendency to leave engagement with the payers too late in the process and assume that the evidence about the product speaks for itself, or fail to provide more direct product education to specific channels.
Building a strategic roadmap for P&R success
Step 1
Step 2
Step 3
Step 4
Step 5
Engage stakeholders and build credibility with key opinion leaders and physicians who will prescribe the product as soon as the target product profile has been established to pressure test any potential data gaps. These stakeholders will vary from product to product.
- If it is an oral or self-administered therapy, the primary driver is payers.
- If a product is physician-administered in the outpatient setting, the product is often purchased in anticipation of administration to a patient, then reimbursed following administration. Physicians and hospitals, therefore, need to ensure the reimbursement is adequate for the price paid. Stakeholders include physicians and hospital decision-makers, including pharmacists, group purchasing organizations, and payers.
- If the product is administered in a hospital during an inpatient stay, the product is reimbursed based on its Diagnosis-Related Group (DRG). If the drug price exceeds the DRG amount, the manufacturer will need to consider other hospital decision-makers, such as group purchasing organizations, pharmacy directors, and hospital reimbursement directors.
Meeting the U.S. P&R moment
A manufacturer can have a great product, but if they don’t understand the U.S. healthcare system and complex nuances of the reimbursement landscape, they will struggle to get payers to support the product or physicians to prescribe it. While it is important to engage with key opinion leaders and physicians to determine if they will prescribe the product, asking payers how they will cover and reimburse the product, as well as any restrictions they may place on that reimbursement, is key to successfully commercializing a product in the U.S.
Manufacturers will also need to be vigilant when it comes to geopolitical developments. Understand how MFN policies and related initiatives may impact how public health entities – Medicare and Medicaid – and commercial payers reimburse products.
A best practice approach is to work with a trusted partner that has the breadth and depth of knowledge and expertise to address the complexities of the U.S. healthcare system, as well as the myriad of P&R issues manufacturers will face.
About the authors:
David Ringger, PhD, is a Director of the Global Market Access and Pricing team at Cencora. With over 12 years of experience in market access, pricing, and health economics across various therapeutic areas and product types, Dr. Ringger brings a wealth of experience and knowledge to his role. He oversees a team focused on formulating evidence-generation plans, developing pricing and reimbursement strategies, and supporting stakeholder engagements. The team collaborates closely with Cencora’s local market access teams to ensure that the global strategies are rooted in local realities.
Ansvarserklæring:
Informasjonen i denne artikkelen utgjør ikke juridisk rådgivning. Cencora, Inc. oppfordrer leserne på det sterkeste til å gjennomgå tilgjengelig informasjon relatert til emnene som diskuteres og stole på sin egen erfaring og ekspertise når de tar beslutninger relatert til dette.
Ta kontakt med teamet vårt
Sources
1. Business Market Insights. US Pharmaceutical Market – Historic data: 2020–2021. https://www.businessmarketinsights.com/reports/us-pharmaceutical-market
2. Medicare Payment Advisory Commission (MedPAC). Part B Drugs Payment System. MedPAC Payment Basics. Published 2024. Revised November 2025. https://www.medpac.gov/wp-content/uploads/2024/10/MedPAC_Payment_Basics_25_PartB_FINAL_SEC.pdf
3. Medicare Payment Advisory Commission (MedPAC). Hospital Acute Inpatient Services Payment System. MedPAC Payment Basics. Published 2024. Revised November 2025. https://www.medpac.gov/wp-content/uploads/2024/10/MedPAC_Payment_Basics_25_hospital_FINAL_SEC.pdf
4. Medicare Payment Advisory Commission (MedPAC). Part D Payment System. MedPAC Payment Basics. Published 2024. Revised November 2025. https://www.medpac.gov/wp-content/uploads/2024/10/MedPAC_Payment_Basics_25_PartD_FINAL_SEC.pdf
5. Centers for Medicare & Medicaid Services. Medicaid Drug Rebate Program: Unit rebate amount calculation. Page last updated 3 February 2026. Accessed 24 February 2026. https://www.medicaid.gov/medicaid/prescription-drugs/medicaid-drug-rebate-program/unit-rebate-amount-calculation
6. McCrear S. PBM reforms signed into law, reshaping Medicare Part D drug pricing transparency. American Journal of Managed Care. Accessed 24 February 2026. Published 3 February 2026. https://www.ajmc.com/view/pbm-reforms-signed-into-law-reshaping-medicare-part-d-drug-pricing-transparency
7. Ungru J. The next phase of vertical integration: wholesalers follow the PBM playbook. Pharmacy Times. Published February 2026. Accessed 24 February 2026. https://www.pharmacytimes.com/view/the-next-phase-of-vertical-integration-wholesalers-follow-the-pbm-playbook
8. Jones, S. National healthcare payer list for providers. MedTrainer. Accessed 24 February 2026. https://medtrainer.com/blog/national-healthcare-payer-list-for-providers/
9. Amin K, Cox C, Ortaliza J, et al. Health care costs and affordability. Health Policy 101. Kaiser Family Foundation. Published October 2025. Accessed 29 December 2025. https://www.kff.org/health-costs/health-policy-101-health-care-costs-and-affordability/?entry=table-of-contents-introduction
10. Centers for Medicare & Medicaid Services. GENEROUS (GENErating cost Reductions fOr U.S. Medicaid) model. Page last modified: 23 December 2025. Accessed 29 December 2025. https://www.cms.gov/priorities/innovation/innovation-models/generous
11. Centers for Medicare & Medicaid Services. GLOBE (Global Benchmark for Efficient Drug Pricing) model. Page last modified: 29 December 2025. Accessed 29 December 2025. https://www.cms.gov/priorities/innovation/innovation-models/globe
12. Centers for Medicare & Medicaid Services. GUARD (Guarding U.S. Medicare Against Rising Drug Costs) model. Page last modified: 29 December 2025. Accessed 29 December 2025. https://www.cms.gov/priorities/innovation/innovation-models/guard
13. U.S. Department of Veterans Affairs. Office of Procurement, Acquisition and Logistics (OPAL). Last updated: January 6, 2022. Accessed 29 December 2025. https://www.va.gov/opal/nac/fss/prospective.asp
