Updated September 8th, 2025
Why the MFN Drug Pricing Policy Matters for Pharmaceuticals
The United States’ Most Favored Nation (MFN) pricing policy has moved from conceptual pilot to federal enforcement. As of July 2025, 17 pharmaceutical manufacturers have received formal notices mandating a 60-day compliance timeline. They include new pricing framework, marking a decisive turning point in U.S. drug pricing regulation.
What changed after MFN enforcement began in July 2025?
MFN is now enforced through compliance letters, expanding beyond its initial executive order stage to apply to Medicare and Medicaid and indirectly to commercial markets and new product launches. U.S. prices now follow OECD benchmarks, launch prices face ceilings from day one, and rebate models are under scrutiny. The changes put immediate downward pressure on high-cost therapies.
What is the impact of MFN on U.S. drug prices?
MFN cuts U.S. list prices by an estimated 25–40%, especially for high-cost therapies. This ends the U.S.’s role as the global margin leader and forces companies to justify pricing with stronger economic and outcomes data.
For pharmaceutical executives navigating the MFN policy, it must be thought of as not only a pricing policy linking domestic prices to a global benchmark. It is a broad reconfiguration of the commercial logic that has historically defined U.S. market access.
Download this policy brief, Most Favored Nation (MFN) and the Future of Pharmaceutical Pricing and Access. The brief outlines the immediate implications for pharmaceutical companies to remain compliant, competitive, and commercially viable in a post-MFN world.
Download the Policy Brief Now
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Reviewed by:
Nic Gwatkin
Principal
Nic is a senior global and regional leader with a proven track record in developing innovative strategies and executing them effectively. Nic has extensive experience in both large-scale and mid-sized pharmaceutical companies, market access, and operational expertise in the EU, US, Japan, and China.
Esther Nzenza
Senior Partner
Esther founded Decisive Consulting in 2020 following 23 years’ experience in the pharma and biotech industry at national, regional, and international levels. Over her career, Esther has built and led Market Access and HEOR organizations and has additionally led all commercial functions across international markets.
Karl Freemyer
SVP, Business Development
Karl leads strategy and implementation, helping pharma and biotech clients address evolving market access challenges. With 15+ years of experience in BD, HEOR, and market access consulting, he also brings commercial expertise from global pharma, diagnostics, as well as market research expertise.