Mike Ryan and I often discuss various U.S. and Global healthcare payment policies that are insufficiently thought through. When modeling is inadequate prior to implementation or is based on faulty assumptions, the unintended consequences and impacts can be quite negative. We’ve decided to share our thoughts periodically on some of these previous or soon-to-be implemented payment policies.

The first of these reviews looks at the unintended consequences of the IRA’s Medicare negotiations on ASP-based Part B in-office administered products. Under the IRA, the drug selection and negotiation for Part B products is scheduled to start on February 1, 2026, with the Medicare Fair Price (MFP) going into effect for all Medicare patients starting on January 31, 2028. So, this review is especially timely.