After failing to obtain the needed votes required to include mandatory MFN legislation in his Big Beautiful Bill, President Trump has looked to other avenues to engage MFN pricing with the pharma industry, a position he signaled clearly in two Executive Orders in April and May 2025. Trump sent letters to 17 pharma manufacturers calling for action to lower drug prices in the U.S. to the lowest MFN rates in developed countries. It is important to recognize that the threat of tariffs and other penalties has had a significant role in the industry’s response to what are essentially “voluntary” programs.

To date 15 manufacturers have reached individual, confidential, MFN agreements with the Trump administration. AbbVie and Regeneron are the only two companies that have not yet reached an MFN-based agreement. While the full terms of these deals have not been released by any manufacturer or the Administration, they appear to involve U.S. access to the lowest MFN pricing seen in developed countries for select drugs and applications, with many being limited to Medicaid use only. In addition, manufacturers have either agreed to launch DTC programs and/or to list their products selectively on Trump Rx. In exchange, pharma manufacturers have been granted a three-year delay in the implementation of potential Trump tariffs and/or the potential FDA fast-tracking of future new drug applications.

A significant concern is that except for obesity drugs where the manufacturers were able to negotiate lower Medicare patient copays, the actual value that these agreements offer patients is highly suspect. For example, several manufacturers have agreed to provide direct to consumer MFN pricing. However, the MFN pricing for many of the products selected exceeds, or is not significantly different from, the current Medicaid price for the product. In addition, MFN exceeds most copay rates for insured patients and doesn’t apply towards the patients Part D OOP cap, and most uninsured patients are unable to pay the MFN prices.

It’s important to put these programs, which are still evolving and subject to public comment, in perspective.

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