March 24, 2026
Rx Pricing: MFN “Deals” & Legal Landmines
Our review of comment submissions for CMS’s most favored nation (MFN) drug pricing model proposals in Medicare Part D (GUARD) and B (GLOBE) leave us with just ~30% odds of their being implemented. The risk…
March 9, 2026
[LNTH] Pylarify 2.0 Payment Pathway
Following FDA approval of LNTH’s Pylarify TruVu late Friday, we continue to expect CMS to provide a three-year transitional pass-through (TPT) payment for hospital outpatient services effective Oct. 1, 2026, with our best estimate on…
December 21, 2025
Rx Model Risks: So Much For “Deals”
CMS’s mandatory Medicare Part D (here) / Part B (here) international drug pricing model proposals released Friday suggest that – besides an ostensible reprieve from as yet unrealized tariffs – recent drug manufacturer “deals” with…
November 5, 2025
[LLY, NVO] Obesity Rx Deal Expectations
Following reports yesterday [here, here] that the White House may announce an agreement with LLY and NVO as early as tomorrow to make obesity products available for $149 / month, “in return for coverage” under…
October 1, 2025
Rx Pricing: More Shoes to Drop or Clearing Event?
The White House’s Rx pricing agreement with PFE yesterday – with the promise of additional company deals next week – may provide industry with some incremental goodwill, but we are dubious that it takes broader…
September 25, 2025
Rx Pricing: MFN Demo Incoming?
The White House’s Office of Management & Budget’s (OMB) disclosure this morning that it is reviewing what appears to be a Most Favored Nation (MFN) drug pricing model is consistent with our long-held expectations, if…
September 10, 2025
Rx Advertising: Policy Quick Take
While we can at this point give no better than tossup odds to FDA plans to curtail direct-to-consumer (DTC) drug advertisements surviving inevitable legal challenges, we caution that the enforcement approach outlined by the agency…
August 12, 2025
Rx Most Favored Nation Company Risks
With President Trump demanding “binding commitments” from drug manufacturers to offer Most Favored Nation (MFN) pricing by Sept. 29, we outline company-specific revenue risks and our expectations for an eventual regulatory proposal in 4Q25 /…
June 18, 2025
Rx Advertisements & RFK: Legal Guardrails
Amid reports that HHS is considering steps to curtail direct-to-consumer (DTC) drug advertisements – with negative implications for high spenders in this area [ABBV, NVO, REGN] – we see significant impediments to how far /…
May 12, 2025
Rx Pricing’s Lucy & the Football Moment?
Investors should view today’s drug pricing Executive Order (EO) with relief, and while the biopharma industry remains on notice for potential future regulatory actions, we suspect the courts would intervene to stop any overly broad…