MFN is producing distinct company response models rather than a common industry template. The differences are becoming as important as the shared policy framework.
- Coverage
- MFN agreements now cover 26 manufacturers and 89% of the branded drug market, according to the White House (September 18, 2026).[5]
- Five participation models
- Companies are using five distinct participation models: selected product and channel commitments, domestic manufacturing investment, broader bilateral arrangements, franchise specific packages and participation by focused and mid sized companies.[2][6][7][8]
- Beyond price
- Reported Pfizer and Lilly terms reach beyond price, touching overseas revenue sharing, tariff treatment and confidentiality.[6][9]
- Tariffs and Medicare
- Pharmaceutical tariffs and Medicare policy now interact with participation: eligible companies with MFN pricing agreements face a zero tariff rate until January 20, 2029, and the GLOBE model begins January 1, 2027.[3][4]
One year in: the company response is becoming clearer
One year after Pfizer announced the first most favored nation (MFN) drug pricing agreement on September 30, 2025,[1] recently reported Pfizer and Eli Lilly deal provisions have added a more complex commercial dimension to the story. For at least some companies, MFN arrangements appear to reach beyond selected U.S. price or access commitments, with reported provisions touching overseas pricing, potential government revenue sharing, tariff treatment, product level structuring and confidential operating terms.
The first year has not produced a uniform pricing response across the sector. Instead, companies are participating through different combinations of product selection, direct channels, domestic investment, tariff and trade management, global pricing oversight and portfolio specific structuring. The latest group of participants (Alcon, Astellas Pharma, BeOne Medicines, BridgeBio, CSL, Kyowa Kirin, Sun Pharma, Teva Pharmaceuticals and UCB) shows that this is no longer only a large pharma response.[2]
Two late September developments add context. The 100% Section 232 tariff on patented pharmaceuticals reached all remaining importers on September 29, and the Centers for Medicare & Medicaid Services (CMS) finalized its GLOBE model for Medicare Part B on September 30.[3][4] Both are examined below because they bear on how companies weigh participation.
This paper draws on public company disclosures, public sector announcements and trade reporting. Agreement terms remain incomplete and company specific; reported features should not be treated as a common contractual template.
Why now: the terms behind the announcements are coming into view
The latest reporting around Pfizer and Eli Lilly has made the structure of MFN participation more visible.[6][9][10] Their reported terms point to commercial considerations that extend beyond the public price narrative, including overseas price mechanics, potential government participation in incremental revenue, tariff related protections and product specific provisions.[6][9][11]
The full contracts remain unavailable and company specific. Public Citizen obtained redacted copies of the Pfizer and Lilly agreements through a Freedom of Information Act request, and the White House has not made the agreements public.[6][9] Even so, the emerging details show why participation must be assessed as a package of commitments, exclusions, operational actions and retained flexibility, not as a headline price concession.
That broader context comes after a year in which participation expanded rapidly. On August 31, Alcon, Astellas Pharma, BeOne Medicines, BridgeBio, CSL, Kyowa Kirin, Sun Pharma, Teva and UCB were announced as joining the framework, having committed to invest at least $19.6 billion collectively in U.S. manufacturing in the near term.[2] Their addition moved MFN participation beyond the initial group of diversified manufacturers and into ophthalmology, oncology, rare disease, plasma derived therapies, generics and specialty pharmaceuticals.
Earlier, Eli Lilly, Novo Nordisk and Regeneron brought biologics focused businesses and high demand GLP-1 franchises into view. Lilly and Novo Nordisk announced their agreements on November 6, 2025,[7][12] and Regeneron followed on April 23, 2026 with a commitment to invest $27 billion in U.S. research, development and manufacturing by 2029.[13] The Lilly and Novo Nordisk arrangements combined access commitments and direct purchase pathways with significant U.S. capacity plans, placing pricing, supply, manufacturing and flagship franchise management within the same visible response package.
The current phase began with Pfizer's agreement in September 2025, followed by AstraZeneca in October,[8] Lilly and Novo Nordisk in November, and a wider group of large manufacturers in December.[14] The early announcements centered on targeted product or channel commitments, often paired with company specific operational, manufacturing or trade considerations. Over the ensuing year, the participant base expanded to 26 manufacturers by September 18, 2026, across a much wider range of business models.[5]
The progression matters because the more useful question is no longer simply which companies have joined the framework. It is how they are choosing to participate, and what the structure of those choices reveals about their portfolios, channels, supply footprints, global pricing exposure and policy priorities.
Five ways companies are participating
Over the first year, five participation models have become visible. They are not mutually exclusive, and the mix appears to vary by portfolio, product category, lifecycle, manufacturing footprint and global market position.
| Model | What it involves | Examples |
|---|---|---|
| 01 Selected product and channel commitments | Participation through defined products and direct channels rather than the whole U.S. portfolio | AstraZeneca, Merck, Novartis, Sanofi [8, 15, 16, 17] |
| 02 Domestic manufacturing and investment commitments | MFN participation paired with visible U.S. manufacturing and R&D investment | Lilly, Novo Nordisk, Regeneron, the August group of nine [2, 7, 13] |
| 03 Broader bilateral arrangements | MFN participation inside a wider commercial arrangement. Reported terms include potential HHS participation in revenue from higher overseas prices (clearest for Pfizer), tariff related protections and extensive confidentiality | Pfizer, Lilly [6, 9, 11, 18] |
| 04 Franchise specific packages | A response built around one high visibility franchise, combining pricing and access, direct purchase pathways and U.S. investment | Lilly and Novo Nordisk (GLP-1s) [7, 12] |
| 05 Participation by focused and mid sized companies | Companies with more focused portfolios across ophthalmology, oncology, rare disease, plasma derived therapies, generics and specialty pharmaceuticals | Alcon, Astellas, BeOne, BridgeBio, CSL, Kyowa Kirin, Sun Pharma, Teva, UCB [2] |
1. Selected product and channel commitments
Some companies are participating through defined products and channels rather than across their entire U.S. portfolio. AstraZeneca said it would offer direct to consumer sales to eligible patients with chronic disease prescriptions at discounts of up to 80% off list prices, and separately would participate in the TrumpRx.gov direct purchasing platform.[8] Merck announced that Januvia, Janumet and Janumet XR will be available to eligible patients at a cash price of approximately 70% off the current list price through a direct to patient program, which operates through its Cash-Pay Gateway site.[15][19] Novartis said it would build direct to patient platforms for Mayzent, Rydapt and Tabrecta, and Sanofi said it would offer certain medicines, including insulins, through TrumpRx.gov and other direct to patient platforms.[16][17]
These actions are built around product selection and route to market design. The key variation is the product chosen, the channel used and the commercial context.
Defined brands, designated programs or direct channels that can sit apart from the wider portfolio.
2. Domestic manufacturing and investment commitments
A second group of companies is combining MFN participation with visible U.S. manufacturing and R&D investment. Lilly announced at least $27 billion in new U.S. manufacturing investments and Novo Nordisk an additional $10 billion, alongside their access and pricing commitments.[7] Regeneron committed $27 billion to U.S. research, development and manufacturing by 2029.[13] The August group of nine companies committed to invest at least $19.6 billion collectively in near term U.S. manufacturing.[2]
- Lilly New U.S. manufacturing$27B at least
- Regeneron U.S. R&D and manufacturing by 2029$27B
- August group of nine Near term U.S. manufacturing$19.6B at least, combined
- Novo Nordisk Additional U.S. investment$10B additional
Company and White House announcements [2] [7] [13]. Bars drawn to one scale in billions of US dollars.
Here, participation is signaled not only through a price or access measure, but also through a tangible domestic footprint. This model is most visible where a company can connect supply, manufacturing expansion and policy engagement in the same package.
Public investment announcements alongside MFN commitments, linking domestic capacity with broader commercial and policy positioning.
3. Broader bilateral arrangements
The Pfizer and Lilly reports indicate a third model: MFN participation as part of a broader bilateral commercial arrangement. Reported terms include potential HHS participation in incremental revenue associated with higher overseas prices, described most clearly for Pfizer's agreement, along with tariff related protections and extensive confidentiality around product and operating details.[6][9][11][18]
Public Citizen's index of the redacted documents lists HHS definitive agreements dated February 23, 2026 for both companies, alongside Department of Commerce letters of agreement on tariff measures.[6] Reporting on those documents also points to product specific provisions, including a carve out for Lilly's GLP-1 obesity drugs and a Pfizer provision that appears to supersede Medicaid's GENEROUS model, although the terms are not fully clear.[9]
This model is defined less by a visible customer access program than by the wider set of reciprocal provisions surrounding the agreement. The publicly available information is limited, but it suggests that the commercial significance of an arrangement cannot be inferred from the price commitment alone. The tariff element now has a visible legal framework, discussed later in this paper.
A company specific package in which pricing, tariffs, global market economics and operating commitments may be considered together.
4. Franchise specific packages for high visibility categories
The Lilly and Novo Nordisk agreements show a fourth model: a response centered on a strategically important, high visibility franchise. Their GLP-1 arrangements combined pricing and access commitments, direct purchase pathways and significant U.S. investment. Lilly announced at least $27 billion in new U.S. manufacturing investments, while Novo Nordisk committed an additional $10 billion, including U.S. production of the Wegovy pill,[7] which the FDA approved on December 22, 2025.[20] Novo Nordisk said it is expected to receive a three year tariff exemption.[12]
This type is distinguished by concentration. The participation model is shaped around the requirements and visibility of one therapy category, rather than a broadly similar response for every product in the company's portfolio.
A category specific package that connects price, access, supply capacity and public commitment around a flagship franchise.
5. Participation by focused and mid sized companies
The August cohort adds a fifth model: participation by companies with more focused portfolios and different operating profiles. Alcon, Astellas, BeOne, BridgeBio, CSL, Kyowa Kirin, Sun Pharma, Teva and UCB span ophthalmology, oncology, rare disease, plasma derived therapies, generics and specialty pharmaceuticals.[2]
The public record does not suggest that these companies have identical obligations or benefits. Their value in the story is that MFN participation now includes companies for which the available response levers, domestic footprint and portfolio breadth may differ materially from those of large diversified manufacturers.
Participation shaped by a narrower franchise set, individual product exposure and a more selective operating model.
What the individual examples show
Pfizer: from first mover to broader package
Pfizer's September 2025 agreement set the initial reference point.[1] The company did not quantify an MFN specific effect on its financials. Its 2026 revenue guidance, reaffirmed on February 3, 2026, reflected the anticipated unfavorable impact of MFN pricing and TrumpRx,[21] and on August 4, 2026 Pfizer raised the guidance midpoint by $500 million, to a range of $60.5 billion to $62.5 billion. The raise reflected stronger non COVID products, partly offset by lower COVID-19 product expectations.[22]
Later reporting has made Pfizer central to the current discussion because its agreement is among the few where reported provisions point beyond price and access to overseas revenue mechanics, tariff treatment and confidential operating terms.[6][9] The White House fact sheet for the original agreement already described an obligation to repatriate increased foreign revenue on existing products that results from U.S. trade policy;[1] the later reporting concerns how HHS may participate in revenue from higher overseas prices.
Pfizer's visible model therefore appears to be the broadest one in the public record: a deal in which U.S. pricing, trade, international markets and company specific protections appear interconnected.
AstraZeneca, Merck, Novartis and Sanofi: targeted commercial offers
AstraZeneca, Merck, Novartis and Sanofi illustrate the selected product and channel model. AstraZeneca's direct to consumer sales for chronic disease prescriptions and separate TrumpRx.gov commitment,[8] Merck's direct to patient diabetes program,[15] and the selected product direct to patient offers from Novartis and Sanofi[16][17] all point to arrangements tied to particular products or defined access routes.
Their common feature is selectivity. Each example shows a public facing commercial action that can be distinguished from a comprehensive change in the company's U.S. portfolio economics.
Lilly and Novo Nordisk: franchise, capacity and access in one response
Lilly and Novo Nordisk show how a high demand category can become the center of an MFN response package. The combination of GLP-1 related access commitments, direct purchase pathways and large U.S. capacity plans is more integrated than a standalone discount or a manufacturing announcement.[7] Novo Nordisk's November 2025 release said it expected an estimated direct, negative low single digit impact on global sales growth in 2026.[12] In August 2026 it raised its 2026 outlook to adjusted sales growth of 0% to minus 6%, driven by higher expected GLP-1 sales.[23]
Their visible response is built around a flagship franchise with supply and policy implications large enough to warrant a coordinated package.
Gilead: a financial materiality signal
Gilead offers a different kind of evidence. Its December 2025 release described a three year agreement that addresses all of the requests made by President Trump, said the financial impact is expected to be manageable, and noted that additional terms remain confidential.[24] In its February 10, 2026 earnings presentation, Gilead estimated a policy impact of about 2% on 2026 HIV sales growth, primarily related to the expiry of Affordable Care Act subsidies, with the drug pricing agreement also included.[25] On October 29, 2026, Gilead raised its 2026 product sales guidance to $31.0 to $31.3 billion, led by HIV, without restating a policy impact.[26] This is less a distinct participation model than an example of how companies are communicating the expected financial effect of participation.
Based on these terms, the company expects the financial impact to be manageable in 2026 and beyond.
The August cohort: expansion beyond diversified pharma
The addition of Alcon, Astellas, BeOne, BridgeBio, CSL, Kyowa Kirin, Sun Pharma, Teva and UCB demonstrates the expansion of participation beyond the largest diversified groups.[2] The cohort does not have a single common commercial profile. Its relevance lies in the breadth of company types now engaged and the visibility of domestic manufacturing commitments as part of that expansion.
Pharmaceutical tariffs and the GLOBE model: two late September variables
Pharmaceutical tariffs: 100% by default, zero for some participants
The Section 232 proclamation signed on April 2, 2026 sets a 100% duty on covered patented pharmaceuticals and their ingredients. The duty applied from July 31, 2026 to companies listed in the proclamation's Annex III, and from September 29, 2026 to other companies. For companies eligible for the proclamation's onshoring rate that have also entered MFN pharmaceutical pricing agreements with HHS, the rate is zero until January 20, 2029.[3]
For participants, tariff treatment therefore appears to be a participation lever, not only a trade matter. Gibson Dunn notes that a signed MFN agreement paired with an approved onshoring plan takes the rate to zero through January 20, 2029.[27] Public Citizen's document index shows Commerce tariff letters of agreement for Pfizer and Lilly,[6] and reporting notes that the exact parameters of these exemptions remain unclear.[9] The schedule varies by company, onshoring status and country of origin, so it is another dimension on which participation models can differ.
The GLOBE model: Medicare Part B exposure and an unsettled link to MFN agreements
On September 30, 2026, CMS finalized the Global Benchmark for Efficient Drug Pricing (GLOBE) model. GLOBE is a mandatory Medicare Part B model that tests a rebate formula for certain drugs in the Part B inflation rebate program, using international drug prices as a benchmark. It runs from January 1, 2027, applies to beneficiaries in a randomly selected set of geographic areas covering about 25% of Original Medicare beneficiaries, and excludes biosimilars and their reference biologics once a biosimilar is on the U.S. market, as well as orphan only drugs, plasma derived products and certain cell and gene therapies.[4][28]
The final model is much narrower than the proposal. AHA News reported that CMS now estimates about $440 million in savings over seven years, down from roughly $12 billion previously, and expects only four manufacturers to be required to participate.[29][30]
According to law firm analyses of the rule, much of the narrowing comes from a waiver: CMS intends to waive mandatory GLOBE participation, quarter by quarter, for manufacturers that also participate in the voluntary GENEROUS Medicaid model.[30][31] CMS's impact estimates assume a waiver for manufacturers that had signed GENEROUS agreements by August 17, 2026, and CMS declined to write an exemption into the rule.[28]
That is a narrower trigger than an MFN agreement as such. PharmaVoice reported before the final rule that some drugmakers believe their agreements exempt them from GLOBE and a proposed Part D counterpart (GUARD), and that the government had not said which companies would be exempt.[32] How individual MFN agreements interact with the final waiver is not visible in the public record.
On October 7, 2026, the Pharmaceutical Research and Manufacturers of America (PhRMA) filed suit in the U.S. District Court for the District of Columbia, challenging the GLOBE rule and asking the court to postpone its November 30, 2026 effective date.[28][33] PhRMA argues that CMS lacks the authority to impose international price benchmarks on Medicare Part B drugs.[33] We found no ruling as of November 3, 2026.
What this adds to the five models
The two developments do not change the central observation; they reinforce it. Tariff treatment appears to give the investment led and bilateral models a concrete trade rationale. The waiver linked to GENEROUS shows that a company's route into the pricing framework can affect its Medicare exposure. Neither mechanism applies uniformly, and the underlying agreements remain largely undisclosed, so these links describe structure that the public record makes visible, not any company's strategy.
What the first year shows
The first year has not established an industry wide pricing template. Instead, it has produced a set of participation types that range from selected product offers and direct channels to domestic investment packages and broader bilateral arrangements. The terms are unevenly disclosed, and the financial effect remains difficult to compare across companies.
That does not reduce the relevance of the pattern. It makes the differences between companies more important. The next disclosures will show whether these early types remain distinct, converge into a clearer market template, or broaden into additional products, channels and future launches.
Frequently asked questions about MFN drug pricing
Sources: the 33 verified links behind this whitepaper
- 01
The White House. “Fact Sheet: President Donald J. Trump Announces First Deal to Bring Most-Favored-Nation Pricing to American Patients.” September 30, 2025. Government source
https://www.whitehouse.gov/fact-sheets/2025/09/fact-sheet-president-donald-j-trump-announces-first-deal-to-bring-most-favored-nation-pricing-to-american-patients/ - 02
The White House. “Fact Sheet: President Donald J. Trump Announces Deal With Nine Additional Pharmaceutical Manufacturers to Lower Drug Prices for Americans.” August 31, 2026. Government source
https://www.whitehouse.gov/fact-sheets/2026/08/fact-sheet-president-donald-j-trump-announces-deal-with-nine-additional-pharmaceutical-manufacturers-to-lower-drug-prices-for-americans/ - 03
The White House. “Adjusting Imports of Pharmaceuticals and Pharmaceutical Ingredients into the United States (Proclamation under Section 232).” April 2, 2026. Government source
https://www.whitehouse.gov/presidential-actions/2026/04/adjusting-imports-of-pharmaceuticals-and-pharmaceutical-ingredients-into-the-united-states/ - 04
Centers for Medicare & Medicaid Services. “CMS Finalizes New Mandatory Drug Payment Model to Deliver Lower Drug Prices for Beneficiaries in Original Medicare Part B.” September 30, 2026. Government source
https://www.cms.gov/newsroom/press-releases/cms-finalizes-new-mandatory-drug-payment-model-deliver-lower-drug-prices-beneficiaries-original - 05
The White House. “Fact Sheet: President Donald J. Trump Announces Lower Drug Prices for All 50 State Medicaid Programs.” September 18, 2026. Government source
https://www.whitehouse.gov/fact-sheets/2026/09/fact-sheet-president-donald-j-trump-announces-lower-drug-prices-for-all-50-state-medicaid-programs/ - 06
Public Citizen. “FOIA documents on the Pfizer and Eli Lilly MFN agreements.” September 19, 2026. Advocacy group, with linked agreement documents
https://www.citizen.org/article/foia-documents-trump-pharma-mfn-drug-pricing-deals/ - 07
The White House. “Fact Sheet: President Donald J. Trump Announces Major Developments in Bringing Most Favored Nation Pricing to American Patients.” November 6, 2025. Government source
https://www.whitehouse.gov/fact-sheets/2025/11/fact-sheet-president-donald-j-trump-announces-major-developments-in-bringing-most-favored-nation-pricing-to-american-patients - 08
AstraZeneca. “AstraZeneca announces historic agreement with US Government to lower the cost of medicines for American patients.” October 10, 2025. Company source
https://www.astrazeneca.com/media-centre/press-releases/2025/astrazeneca-announces-historic-agreement-with-us-government-to-lower-the-cost-of-medicines-for-american-patients.html - 09
Fierce Pharma. “New MFN deal details reignite concerns that Trump’s pricing policy favors pharma.” September 21, 2026. Secondary reporting
https://www.fiercepharma.com/pharma/new-mfn-deal-details-reignite-concerns-trumps-pricing-policy-favors-pharma - 10
The Washington Post. “Secret contracts reveal undisclosed terms in Trump’s drug-pricing deals.” September 19, 2026. Secondary reporting
https://www.washingtonpost.com/politics/2026/09/19/secret-contracts-reveal-undisclosed-terms-trumps-drug-pricing-deals/ - 11
Endpoints News. “Pfizer, Lilly ‘most favored nation’ deals to give US share of raised foreign prices.” September 21, 2026. Secondary reporting (paywalled)
https://endpoints.news/pfizer-lilly-most-favored-nation-deals-to-give-us-share-of-raised-foreign-prices/ - 12
Novo Nordisk. “Novo Nordisk announces agreement with the U.S. Administration to bring GLP-1s to more Americans at a lower cost.” November 6, 2025. Company source
https://www.novonordisk.com/content/nncorp/global/en/news-and-media/news-and-ir-materials/news-details.html?id=916450 - 13
The White House. “Fact Sheet: President Donald J. Trump Announces Deal with Regeneron to Bring Most-Favored-Nation Pricing to American Patients.” April 23, 2026. Government source
https://www.whitehouse.gov/fact-sheets/2026/04/fact-sheet-president-donald-j-trump-announces-deal-with-regeneron-to-bring-most-favored-nation-pricing-to-american-patients/ - 14
The White House. “Fact Sheet: President Donald J. Trump Announces Largest Developments to Date in Bringing Most-Favored-Nation Pricing to American Patients.” December 19, 2025. Government source
https://www.whitehouse.gov/fact-sheets/2025/12/fact-sheet-president-donald-j-trump-announces-largest-developments-to-date-in-bringing-most-favored-nation-pricing-to-american-patients/ - 15
Merck. “Merck Reaches Agreement With U.S. Government to Expand Access to Medicines and Lower Costs for Americans (press release, PDF).” December 19, 2025. Company source
https://s2.q4cdn.com/584635680/files/doc_news/Merck-Reaches-Agreement-With-U-S--Government-to-Expand-Access-to-Medicines-and-Lower-Costs-for-Americans-2025.pdf - 16
Novartis. “Novartis and US government reach agreement on lowering drug prices in the US.” December 19, 2025. Company source
https://www.novartis.com/news/media-releases/novartis-and-us-government-reach-agreement-lowering-drug-prices-us - 17
Sanofi. “Sanofi reaches agreement with the US government to lower medicine costs while strengthening innovation.” December 19, 2025. Company source
https://www.sanofi.com/en/media-room/press-releases/2025/2025-12-19-19-21-43-3208697 - 18
Bloomberg. “Pfizer to share revenue with HHS in deal on overseas drug prices.” September 19, 2026. Secondary reporting
https://www.bloomberg.com/news/articles/2026-09-19/pfizer-to-share-revenue-with-hhs-in-deal-on-overseas-drug-prices - 19
Merck. “Merck Cash-Pay Gateway (program website).” accessed November 3, 2026. Company source
https://www.merckcashpaygateway.com/ - 20
Novo Nordisk. “Wegovy® pill approved in the US as first oral GLP-1 for weight management (Form 6-K).” December 22, 2025. Company filing
https://www.sec.gov/Archives/edgar/data/353278/000117184325008080/f6k_122225.htm - 21
Pfizer. “Fourth-quarter and full-year 2025 results (earnings release, SEC Exhibit 99).” February 3, 2026. Company filing
https://www.sec.gov/Archives/edgar/data/78003/000007800326000005/pfe-12312025xex99.htm - 22
Pfizer. “Second-quarter 2026 results (earnings release, SEC Exhibit 99).” August 4, 2026. Company filing
https://www.sec.gov/Archives/edgar/data/78003/000007800326000094/pfe-6282026xex99.htm - 23
Novo Nordisk. “Novo Nordisk raises adjusted sales and adjusted operating profit outlook for 2026.” August 4, 2026. Company source (via BioSpace)
https://www.biospace.com/press-releases/novo-nordisk-raises-adjusted-sales-and-adjusted-operating-profit-outlook-for-2026 - 24
Gilead Sciences. “Gilead and U.S. Government Enter Agreement to Lower Costs of Medicines for Americans.” December 19, 2025. Company source
https://www.gilead.com/news/news-details/2025/gilead-and-u-s--government-enter-agreement-to-lower-costs-of-medicines-for-americans - 25
Gilead Sciences. “Q4 and Full Year 2025 Earnings Presentation.” February 10, 2026. Company source
https://s29.q4cdn.com/585078350/files/doc_financials/2025/q4/GILD-Q4-FY25-Earnings-Presentation-10-February-2026.pdf - 26
Gilead Sciences. “Gilead Sciences Announces Third Quarter 2026 Financial Results.” October 29, 2026. Company source
https://www.gilead.com/news/news-details/2026/gilead-sciences-announces-third-quarter-2026-financial-results - 27
Gibson Dunn. “MFN Goes Mid-Market: Nine More Drugmakers Sign Medicaid Pricing Deals as the September 29 Tariff Deadline Approaches.” September 1, 2026. Law firm analysis
https://biotechbriefings.gibsondunn.com/?p=7097 - 28
Federal Register (CMS). “Global Benchmark for Efficient Drug Pricing (GLOBE) Model, final rule, 91 FR 62936 (public inspection September 30, 2026).” published October 2, 2026. Government source
https://www.federalregister.gov/documents/2026/10/02/2026-20281/global-benchmark-for-efficient-drug-pricing-globe-model - 29
AHA News. “CMS finalizes GLOBE drug pricing model.” October 1, 2026. Secondary reporting
https://www.aha.org/news/headline/2026-10-01-cms-finalizes-globe-drug-pricing-model - 30
Skadden. “CMS Finalizes the GLOBE Model: A Most-Favored-Nation Drug Payment Framework for Medicare Part B.” October 2026. Law firm analysis
https://www.skadden.com/insights/publications/2026/10/cms-finalizes-the-globe-model - 31
Covington. “CMS Finalizes MFN Pricing in Medicare Part B Through GLOBE Model.” October 2026. Law firm analysis
https://www.cov.com/en/news-and-insights/insights/2026/10/cms-finalizes-mfn-pricing-in-medicare-part-b-through-globe-model - 32
PharmaVoice. “A hidden tradeoff in Trump’s MFN drug deals.” September 21, 2026. Secondary reporting
https://www.pharmavoice.com/news/trump-mfn-drug-deals-medicare-savings/830807/ - 33
Becker’s Hospital Review. “PhRMA sues to block CMS’ international drug pricing model.” October 8, 2026. Secondary reporting
https://www.beckershospitalreview.com/pharmacy/phrma-sues-to-block-cms-international-drug-pricing-model/
Method notes: This paper analyzes public company statements, government announcements and industry reporting. This paper uses sources published through October 29, 2026, rechecked for developments through November 3, 2026, including the Section 232 tariff schedule and the CMS GLOBE final rule. The underlying agreements are not uniformly public, and several material provisions remain redacted or undisclosed. The analysis identifies observed response patterns; it does not infer that any individual term is common to all participating companies.
Source types: government and company documents are primary sources. Trade reporting, advocacy group analysis and law firm analysis are secondary and are labeled as such. Where a statement rests only on secondary sources, the text attributes it.
Hero photograph: cottonbro studio / Pexels.