Health Affairs October 8, 2025
On September 30, 2025, the Centers for Medicare & Medicaid Services (CMS) published the final guidance for the third cycle of the Medicare Drug Price Negotiation Program, initial price applicability year (IPAY) 2028. This guidance release occurred on the same day as a more heavily publicized drug pricing announcement, although the morning announcement contained a relative paucity of details when compared to the 381-page final guidance.
Although the final guidance is focused on policies for the 2028 cycle, it also includes policies regarding the effectuation of any negotiated Maximum Fair Prices (MFPs) for the first three cycles of the program. It is important to remember that CMS is currently administering three separate cycles of the program. The agency is working...
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