The Inflation Reduction Act directed the Centers for Medicare & Medicaid Services (CMS) to negotiate drug prices for 10 drugs covered by Medicare Part D for the 2026 plan year. Those drugs were selected in 2023, negotiated in 2024, and the official Maximum Fair Prices (MFP) that will be used in 2026 are now published.
The following table provides the negotiated 30-day MFP values for these 10 drugs.
These values will not be the transactional values for pharmacies, PBMs, manufacturers, patients, or other intermediaries. CMS has included additional detail at the NDC level that provides the package-level MFP values that were determined through the CMS established calculation.
CMS provides a spreadsheet with 141 NDCs across the 10 drugs with those specific MFP values. PHSL analyzed these values and has identified several points to highlight. First, none of the 30-day negotiated values are equal to any single NDC MFP value. Second, these MFP values may not be the full transaction price for a pharmacy or patient because dispensing fees can be a part of the transaction price.
Initial comparisons between MFP at the NDC level and the current published WAC values provide some unique insights. Novolog has an MFP that is 3.8% less than the current WAC, which was reduced at the beginning of 2024, meaning that the negotiated pricing is not likely to lead to additional savings. The Entresto sprinkle capsule NDC MFPs are WAC-89%, which is the deepest discount measured at the NDC level. Conversely, one Xarelto NDC for a single 2.5mg tablet in a blister pack currently lists an MFP value that is over three times greater than the current WAC value. We will have to wait to see if this is an error or a function of the weighting calculations used by CMS.
The Imbruvica MFPs demonstrate the impact of the negotiation, unique NDCs, and CMS’s weighting calculations. The Imbruvica 140 mg capsules appear to be the most expensive per the MFP package price ($14,160.12), but when comparing at the unit level (per capsule) the capsule NDC ($118.00) is less expensive than the Imbruvica 140 mg tablet NDC unit MFP ($353.93). Medicare beneficiaries who are paying a coinsurance for Imbruvica 140 mg could experience a lower cost with the capsules ($3,304.03 MFP for 28 capsules vs. $9,909.99 MFP for 28 tablets), but this would likely require the pharmacy to dispense only a portion of the package, leaving a partial package on the shelf.
An additional factor for patients will be insulin coverage. Medicare requires a maximum patient cost of $35 per month for insulin and any insulin product with an MFP has an additional calculation on the maximum patient cost. Insulin aspart in 2026 will have an MFP and the maximum monthly patient cost is the lower of $35 or 25% of the MFP. The Insulin aspart products (Fiasp, Novolog, and insulin aspart) will experience the 25% of MFP for patient costs depending on the quantity dispensed. Without taking pharmacy dispensing fees into account, all insulin aspart products will have a patient cost that is less than $35 in 2026. Unbranded insulin aspart vials could be as low as $8.70 per vial per month, and a pack of 5 pens could be as low as $16.16. Novolog and Fiasp patient costs would be higher at $17.39 per vial and $33.59 per pack of 5 pens. Patient costs can be lower depending on the plan sponsor benefit design.
Furthermore, if generics or biosimilars are available in early 2025 for any of these products, the MFP may not be utilized, and Medicare Part D plans will be permitted to cover the generics or biosimilars. Several of these products could experience generic or biosimilar competition. If any delays occur and competition does not enter the market until later in 2025 or in 2026, the MFP values would be valid and utilized for part or all of 2026 depending on the timing.
How will Medicare Part D plan sponsors and Medicare Advantage plans utilize the MFP drugs to service beneficiaries? What challenges will arise in 2026? What drugs will be announced as the selected products for 2027 negotiations? Contact us for customized analysis and education on MFPs and their impacts.
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