Overview
The last half-decade has seen huge changes in the provision of healthcare to Americans. Recent developments in the public healthcare landscape from the COVID-19 pandemic, the implementation of new regulations, such as provisions from the Inflation Reduction Act, and societal shifts in the healthcare delivery model toward telehealth and in-home care have all influenced where and how we pay for healthcare.
Medicare and Medicaid health expenditures accounted for about 6.9% of the United States GDP in 2023. The sheer size of these programs translates to market power. According to the American Hospital Association, 96% of US hospitals rely on Medicare and Medicaid to pay for over 50% of their total inpatient days.1American Hospital Association, “Fact Sheet: Majority of Hospital Payments Dependent on Medicare or Medicaid”, updated May 6, 2024, accessed April 30, 2025. https://www.aha.org/fact-sheets/2022-05-25-fact-sheet-majority-hospital-payments-dependent-medicare-or-medicaid A financial analysis of the largest seven US health insurers found that three of them (Humana, Centene, and Molina) receive over 85% of their plan revenues from government programs.2Wendell Potter, “BIG INSURANCE 2022: Revenues reached $1.25 trillion thanks to sucking billions out of the pharmacy supply chain – and taxpayers’ pockets”, Health Care un-covered, February 27, 2023, accessed April 30, 2025. https://healthcareuncovered.substack.com/p/big-insurance-2022-revenues-reached With this reliance on government healthcare funding, the healthcare industry is incentivized to build their business models to support Medicare and Medicaid services.
While Rios Partners’ annual Health of Health Index report provides a holistic evaluation of the state of US healthcare through the four pillars – Patient, Payer, Provider, and R&D – this brief highlights trends in Medicare and Medicaid spending that signal shifts in the overall healthcare ecosystem. As the new U.S. administration considers policy changes impacting the provision of Medicare and Medicaid, this brief aims to provide identify spending trends, important policy context, and directional recommendations to respond to observed trends in the following areas:
- Prescription drugs: Market incentives to raise drug prices and structural changes to Medicare and Medicaid have resulted in spending growth at twice the rate of overall expenditures.
- Medical equipment: An aging US population is receiving more home health care services, driving up demand for at-home medical equipment to manage chronic conditions.
Prescription Drugs
Americans pay more for prescriptions drugs than any of their peers. In 2022, the US paid almost three times as much for prescription drugs as Organisation for Economic Co-operation and Development (OECD) comparison countries.3Sonal Parasrampuria and Stephen Murphy, “Comparing U.S. and International Market Size and Average Pricing for Prescription Drugs, 2017-2022: Issue Brief”, Office of the Assistant Secretary for Planning and Evaluation, December 2024, accessed May 13, 2025, https://www.ncbi.nlm.nih.gov/books/NBK611829/ This gap is growing, with per unit prices on the top 50 drugs jumping from 5.7 times as much as OECD countries in 2017 to 9.1 times as much in 2022. Prescription drug costs are a top health concern for the American public. 92% of Americans believe it’s important for the new administration to expand drug price negotiations, according to a recent KFF survey.4Ashley Kirzinger et al., “KFF Health Tracking Poll: Public Weighs Health Care Spending and Other Priorities for Incoming Administration”, KFF, January 17, 2025, accessed April 30, 2025. https://www.kff.org/health-costs/poll-finding/kff-health-tracking-poll-public-weighs-health-care-spending-and-other-priorities-for-incoming-administration/ The Payer pillar highlighted a 2.8% increase in out-of-pocket expenses as well as a 14.7% increase in the number of US adults who are rationing medication due to costs.
Two recent Executive Orders on April 15, 2025 and May 12, 2025 asked CMS officials to evaluate drug pricing for Medicare and Medicaid beneficiaries and inefficiencies in the pharmaceutical supply chain with the goal of reducing drug costs for Americans.5The White House, “Lowering Drug Prices by Once Again Putting Americans First,” Executive Order 14273, April 15, 2025, accessed April 30, 2025. https://www.whitehouse.gov/presidential-actions/2025/04/lowering-drug-prices-by-once-again-putting-americans-first/,6The White House, “Delivering Most-Favored-Nation Prescription Drug Pricing to American Patients”, Executive Order, May 12, 2025, accessed May 13, 2025, https://www.whitehouse.gov/presidential-actions/2025/05/delivering-most-favored-nation-prescription-drug-pricing-to-american-patients/ Efforts to rein in drug pricing aren’t new. Congress, in conjunction with the Centers for Medicare & Medicaid Services (CMS), has been trying to control government prescription drug spending for decades. The Medicaid Drug Rebate Program (MDRP), adopted in 1990, requires drug manufacturers to pay the government back part of the cost of outpatient drugs in exchange for their drugs’ coverage under Medicaid.7 Medicaid.gov, “Medicaid Drug Rebate Program (MDRP),” Medicaid.gov, updated February 21, 2025, accessed April 28, 2025. https://www.medicaid.gov/medicaid/prescription-drugs/medicaid-drug-rebate-program Last year, Section 9816 of the American Rescue Plan Act removed the rebate cap on covered drugs to control what the government pays for brand name drugs whose rebates had already reached 100% of the average manufacturer price.8American Rescue Act of 2021, H.R.1319, 117th Cong. (2021). https://www.congress.gov/bill/117th-congress/house-bill/1319 In addition to incremental changes to the MDRP, the Inflation Reduction Act (IRA) provided Medicare with the ability to directly negotiate drug prices. Also last year, CMS negotiated Maximum Fair Prices (MFPs) for 10 Medicare Part D drugs and estimated that 2023 Medicare spending on these drugs would have decreased by $6 billion had the MFPs been in effect.9Centers for Medicare & Medicaid Services, “Medicare Drug Price Negotiation Program: Negotiated Prices for Initial Price Applicability Year 2026”, Fact Sheets, August 15, 2024, accessed April 24, 2025. https://www.cms.gov/newsroom/fact-sheets/medicare-drug-price-negotiation-program-negotiated-prices-initial-price-applicability-year-2026
By the Numbers
Prescription drug spending has grown at twice the rate of overall spending.
According to the latest National Health Expenditure (NHE) data from the Centers for Medicare & Medicaid Services (CMS), Medicare spent $144.6 billion on prescription drugs in 2023, representing 14% of total Medicare spending while Medicaid spent $51 billion on prescription drugs in 2023, about a 6% share of its total spending. Public payer spending on prescription drugs has grown rapidly over the last 5 years: Medicare and Medicaid expenditures on prescription drugs grew twice as fast as overall spending from 2019 to 2023. In contrast, during the same period, private insurance prescription drug expenditures grew at the same rate as overall spending. This indicates meaningful differences between private and public payer policies on prescription drugs.

Table 1. 2023 Prescription Drug Spending Changes by Source10All dollar amounts are reported in 2023 real dollars. Centers for Medicare & Medicaid Services, “National Health Expenditure Data: Historical, NHE Tables,” “Table 04 National Health Expenditures by Source of Funds and Type of Expenditures,” updated December 18, 2024, accessed April 22, 2025, https://www.cms.gov/data-research/statistics-trends-and-reports/national-health-expenditure-data/historical, 11Centers for Medicare & Medicaid Services, “Quick Definitions for National Health Expenditure Accounts (NHEA) Categories”, accessed April 24, 2025. https://www.cms.gov/files/document/quick-definitions-national-health-expenditures-accounts-nhea-categories.pdf
| Spending Source12 All dollar amounts are in 2023 real dollars. Please note that the Centers for Medicare & Medicaid Services (CMS) publishes National Health Expenditure (NHE) data in December from the previous calendar year. That means CY 2023, the latest year for NHE, was published in December 2024. | Medicare | Medicaid | Private |
| 2023 Overall | $1.03 trillion | $871.7 billion | $1.46 trillion |
| Change since 2022 | 4.6% | 4.5% | 7.9% |
| Change since 2019 | 7.2% | 18.7% | 6.4% |
| 2023 Prescription Drugs13 The “Prescription Drugs” category Covers the “retail” sales of human-use dosage-form drugs, biological drugs, and diagnostic products that are available only by a prescription. | $144.6 billion | $51 billion | $175.5 billion |
| Change since 2022 | 8.5% | 8% | 10.1% |
| Change since 2019 | 15.8% | 34.8% | 6.5% |
Drug Price Drivers
Drug producer prices have increased at three times the rate of inflation.
Market structures have incentivized private drug manufacturers, wholesalers, and pharmacies to raise drug prices. A November 2024 HHS report to Congress highlighted increased manufacturer list drug prices for over 4,200 products in 2022, 46% of which outpaced inflation.14U.S. Department of Health and Human Services Office of the Assistant Secretary for Planning and Evaluation, “Prescription Drug Spending, Pricing Trends, and Premiums in Private Health Insurance Plans”, November 2024, accessed April 24, 2025. https://www.dol.gov/sites/dolgov/files/ebsa/laws-and-regulations/laws/no-surprises-act/2024-report-to-congress-prescription-drug-spending.pdf Over the last 40 years, the prices producers charge for pharmaceuticals have increased at three times the rate of inflation, with life-saving cardiovascular drugs in 2023 costing 450% of what they cost in 2002.15 USAFacts, “Drug prices have outpaced inflation since the 1980s”, USAFacts, updated March 21, 2025, accessed May 1, 2025. https://usafacts.org/articles/drug-prices-outpaced-inflation-since-the-1990s/
The profits from these transactions are distributed across stakeholders. A 2025 study of provider-administered drugs found that 74% of the net spending retained from drug spending was captured by manufacturers, with providers capturing the majority of the remaining retention (22%).16 J. Daniel McGeeney, Shruti Rathnavel, and Aylin Sertkaya, “Profit Margins of Pharmaceutical Supply Chain Entities on Provider-Administered Drugs in Outpatient and Physician Settings”, Office of the Assistant Secretary for Planning and Evaluation, January 10, 2025, accessed May 13, 2025, https://www.ncbi.nlm.nih.gov/books/NBK611874/
Health insurance plans often institute rebate agreements to claim some of the profits in the pharmaceutical supply chain in exchange for drug coverage on their formularies. This figure from a 2024 GAO report shows how funds flow to get plan members the drugs they are prescribed. 17GAO, “Figure 1: Example of the Flow of Funds and Prescription Drugs through the Supply Chain When a Health Plan Member Purchases a Drug through a Pharmacy Benefit Manager (PBM)”, PRESCRIPTION DRUGS: Selected States’ Regulation of Pharmacy Benefit Managers, p.9, March 2024, accessed May 13, 2025, https://www.gao.gov/assets/gao-24-106898.pdf
Figure 2. Flow of Funds and Prescription Drugs through the Supply Chain to a Health Plan Member18 GAO, “Figure 1: Example of the Flow of Funds and Prescription Drugs through the Supply Chain When a Health Plan Member Purchases a Drug through a Pharmacy Benefit Manager (PBM)”, PRESCRIPTION DRUGS: Selected States’ Regulation of Pharmacy Benefit Managers, p.9, March 2024, accessed May 13, 2025, https://www.gao.gov/assets/gao-24-106898.pdf

Pharmacy benefit managers (PBMs) sit at the center of the market as price negotiators working on behalf of plan sponsors and collecting partial payments and rebates from manufacturers, pharmacies, and the health plan.
Pharmacy Benefit Manager Incentives
For every $1 increase in drug manufacturer rebates, drug list prices increase by $1.17.
PBMs have attracted a lot of recent attention for their role in the pricing of and access to drugs for Americans. A healthcare innovation of the 1960’s, PBMs were established to regulate the expansion of prescription insurance coverage by designing drug formularies and negotiating prices of drugs with manufacturers, wholesalers, and pharmacies on behalf of insurance plan sponsors.19Mattingly TJ, Hyman DA, Bai G. Pharmacy Benefit Managers: History, Business Practices, Economics, and Policy. JAMA Health Forum. 2023;4(11):e233804. doi:10.1001/jamahealthforum.2023.3804 What was originally a cost savings role has warped into an oft-cited cause of drug price inflation. In their November 2024 report to Congress, HHS detailed market incentives for PBMs to drive prescription drug prices higher.20U.S. Department of Health and Human Services Office of the Assistant Secretary for Planning and Evaluation, “Prescription Drug Spending, Pricing Trends, and Premiums in Private Health Insurance Plans”, November 2024, accessed April 24, 2025. https://www.dol.gov/sites/dolgov/files/ebsa/laws-and-regulations/laws/no-surprises-act/2024-report-to-congress-prescription-drug-spending.pdf Two recent interim reports from the Federal Trade Commission (FTC) focused on the impact of vertical integration of PBMS in the prescription drug supply chain on drug prices.21 U.S. Federal Trade Commission, “Pharmacy Benefit Managers: The Powerful Middlemen Inflating Drug Costs and Squeezing Main Street Pharmacies,” July 2024, accessed April 29, 2025. https://www.ftc.gov/system/files/ftc_gov/pdf/pharmacy-benefit-managers-staff-report.pdf,22U.S. Federal Trade Commission, “Specialty Generic Drugs: A Growing Profit Center for Vertically Integrated Pharmacy Benefit Managers”, January 2025, accessed April 29, 2025. https://www.ftc.gov/system/files/ftc_gov/pdf/PBM-6b-Second-Interim-Staff-Report.pdf
PBMs make money through their negotiations with drug manufacturers, health insurers, and pharmacies.23Bollmeier SG, Griggs S. The Role of Pharmacy Benefit Managers and Skyrocketing Cost of Medications. Mo Med. 2024 Sep-Oct;121(5):403-409. PMID: 39421485; PMCID: PMC11482839. https://pmc.ncbi.nlm.nih.gov/articles/PMC11482839/ Many of these agreements result in rebate sharing, where an amount from drug sales are returned to PBMs in exchange for their services. These rebates are often structured as percentages of list prices, which means that the higher the list price, the higher the rebate. In fact, for every $1 increase in drug manufacturer rebates, drug list prices increase by $1.17.24Neeraj Sood et al., “The Association between Drug Rebates and List Prices”, USC Leonard D. Schaeffer Institute for Public Policy & Government Service, February 11, 2020, accessed May 1, 2025. https://schaeffer.usc.edu/research/the-association-between-drug-rebates-and-list-prices/ Since PBMs determine the drug formulary structure for insurance plans, they have clear financial incentives to favor placement of higher priced drugs over cheaper alternatives. A GAO report in 2023 found PBMs received higher rebates for placing manufacturer drugs in lower formulary tiers with fewer competitors, demonstrating the mutual financial benefit of drug coverage negotiations for manufacturers and PBMs.25John Dicken, “MEDICARE PART D: CMS Should Monitor Effects of Rebates on Plan Formularies and Beneficiary Spending”, United States Government Accountability Office, September 2023, accessed May 1, 2025. https://www.gao.gov/assets/gao-23-105270.pdf
Another driver of higher drug prices by PBMs comes from the practice of spread pricing, where prices charged to health plans are greater than the reimbursement sent to the pharmacy. The spread of these prices becomes profit for PBMs. An evaluation of Part D high-utilization generic drugs found 40% of average claim spending went to PBM gross profits.26T. Joseph Mattingly et al., “Pharmacy Benefit Manager Pricing and Spread Pricing for High-Utilization Generic Drugs,” JAMA Health Forum, October 20, 2023, accessed May 1, 2025. https://jamanetwork.com/journals/jama-health-forum/fullarticle/2810783 CMS is aware of this practice and has required Medicaid and CHIP PBM subcontractors to report spread pricing so they can reduce rebate payments by an equivalent amount.27Centers for Medicare & Medicaid Services, “CMS Issues New Guidance Addressing Spread Pricing in Medicaid, Ensures Pharmacy Benefit Managers are not Up-Charging Taxpayers”, Press Releases, May 15, 2019, accessed May 1, 2025. https://www.cms.gov/newsroom/press-releases/cms-issues-new-guidance-addressing-spread-pricing-medicaid-ensures-pharmacy-benefit-managers-are-not As of January 2025, 16 states have prohibited spread pricing, indicating increased awareness of the impacts on Medicaid spending.28Lisa Kimbrough, “State PBM Reform: How States Are Trying to Control Pharmaceutical Spending”, MultiState, January 6, 2025, accessed May 1, 2025. https://www.multistate.us/insider/2025/1/6/state-pbm-reform-how-states-are-trying-to-control-pharmaceutical-spending Although no federal ban on spread pricing exists, the bi-partisan sponsored “Protecting Pharmacies in Medicaid Act” introduced in March 2025 by Senator Peter Welch includes a section prohibiting spread pricing to ensure drug payments are passed through to pharmacies.29“Protecting Pharmacies in Medicaid Act”, S.927, 119th Cong., introduced March 11, 2025, accessed May 1, 2025. https://www.congress.gov/bill/119th-congress/senate-bill/927/text
Vertical Integration and Consolidation in the Pharmacy Supply Chain
3 PBMs manage 80% of all prescriptions filled.
Through various mergers and consolidations, three PBMs (Caremark Rx, Express Scripts, and Optum Rx) now manage about 80 percent of all prescriptions filled, granting them significant market power to manipulate prices to maximize profits.30Kristi Martin, “What Pharmacy Benefit Managers Do, and How They Contribute to Drug Spending,” The Commonwealth Fund, March 17, 2025, accessed April 28, 2025. https://www.commonwealthfund.org/publications/explainer/2025/mar/what-pharmacy-benefit-managers-do-how-they-contribute-drug-spending These large PBMs are vertically integrated with insurance plans (Aetna with CVS Caremark, Cigna with Express Scripts, and United Healthcare with Optum Rx), which grants insurers more control over drug formularies while streamlining prescription drug benefit management.31Adam Fein, “Mapping the Vertical Integration of Insurers, PBMs, Specialty Pharmacies, and Providers: DCI’s 2025 Update and Competitive Outlook”, Drug Channels, April 9, 2025, accessed Since Medicare and Medicaid subcontract out to PBMs and partner with private insurers to offer coverage, they cannot take advantage of the administrative benefits of managing all aspects of prescription drug coverage under one roof. While fully integrated healthcare companies absorb the administrative costs since they would be “paying themselves,” Medicare and Medicaid are changed administrative fees for each processed claim, further raising prices for public payers.
While vertical integration increases business efficiency, it also creates structures that limit drug patient options. Insurers and PBMs are owned by healthcare companies that operate specialty and retail pharmacies. As part of negotiations, PBMs often create preferred pharmacy networks that offer patients lower out-of-pocket costs and increased access to drugs when filling at in-network pharmacies. For specialty drugs, some formularies require patients to fill prescriptions at PBM-affiliated pharmacies and, in some cases, require providers administering medications in a clinical setting to order medications through their affiliated pharmacies. This lowers consumer prices of drugs and increases their access to their prescribed medications at preferred locations at the expense of flexibility. Independent or other out-of-network pharmacies are often left out of the loop, not carrying the right medication or offering it at a higher price point.32U.S. Federal Trade Commission, “Pharmacy Benefit Managers: The Powerful Middlemen Inflating Drug Costs and Squeezing Main Street Pharmacies,” July 2024, accessed April 29, 2025. https://www.ftc.gov/system/files/ftc_gov/pdf/pharmacy-benefit-managers-staff-report.pdf This market structure creates downward pressure on reimbursement rates for out-of-network pharmacies to a level that can become unsustainable for smaller, independent pharmacies, effectively eliminating rival pharmacies and patient choice with it.
This level of market coordination has drawn significant scrutiny from government regulators. On November 26, 2024, the FTC filed a suit against PBMs for engaging in harmful artificial price inflation of insulin.33 “In the Matter of Caremark Rx, LLC, Zinc Health Services, LLC, Express Scripts, Inc., Evernorth Health, Inc., Medco Health Services, Inc., Ascent Health Services LLC, OptumRx, Inc., OptumRx Holdings, LLC, and Emisar Pharma Services LLC”, Docket No. 9437, Federal Trade Commision, November 26, 2024, accessed May 1, 2025. https://www.ftc.gov/system/files/ftc_gov/pdf/612314.2024.11.26_part_3_administrative_complaint_-_revised_public_redacted_version.pdf A stay order due to FTC vacancies has halted administrative adjudication on this matter, but other offices have moved forward with independent suits. Most recently, the Michigan Department of Attorney General filed a suit against PBMs for engaging in anti-competitive practices that allegedly created pharmacy deserts across the state of Michigan.34“Michigan v. Express Scripts, Inc., Evernorth Health, Inc., and Prime Therapeutics LLC”, No. 2:25-cv-11215-JJCG-KGA, E.D. Mich., April 28, 2025, accessed May 1, 2025. https://www.michigan.gov/ag/-/media/Project/Websites/AG/releases/2025/April/Express-Scripts-Complaint.pdf These suits aim to limit the market power of integrated pharmaceutical distribution, which is critical for controlling spending by public plans who cannot integrate.
Supply Chain Disruptions – Drug Shortages
Drug shortages put upward pressure on prices.
Increases in demand for certain drugs, such as diabetes and obesity treatments, along with changes to complex international pharmaceutical supply chains, have put upward pressure on drug prices. See the Health of Health 2024 Securing the US Pharmaceutical Supply Securing the US Pharmaceutical Supply Chain Chain topic deep dive for more information. S and Medicaid have influenced spending as well. Insulin spending caps for Medicare Part D beneficiaries and continuous Medicaid enrollment during the pandemic contributed to recent spending.
Absorbing Higher Prices Through Updated Medicare Benefits
While most prescription drug provisions in the IRA aren’t reflected in expenditure data yet, insulin caps contributed to Medicare 2023 spending.
The IRA includes multiple provisions focused on lowering prescription drug costs for Medicare beneficiaries.35Centers for Medicare & Medicaid Services, “Inflation Reduction Act: CMS Implementation Timeline”, accessed April 30, 2025. https://www.cms.gov/files/document/10522-inflation-reduction-act-timeline.pdf In 2023, the most recent year of NHE data, Medicare capped out-of-pocket spending for insulin at $35 per month. In 2024, 5% coinsurance was eliminated from Medicare catastrophic coverage. 2025 is the first year with a $2,000 annual out-of-pocket spending cap on covered prescription drugs for Medicare Part D beneficiaries. These changes are expected to drive prescription spending growth for Medicare as it foots the bill for beneficiaries with the highest level of medical needs.36 Centers for Medicare & Medicaid Services, “Forecast Summary”, National Health Expenditure Projects 2023-2032, accessed April 30, 2025. https://www.cms.gov/files/document/nhe-projections-forecast-summary.pdf Looking toward the future, Medicare’s drug price negotiations coming into 2026 and beyond will likely result in decreased revenue from drug manufacturer rebates, although the savings from lowered list prices are expected to save Medicare billions of dollars.
Enrolling More Americans in Health Insurance
Medicaid drug spending per enrollee grew 7.3% from 2019 to 2023.
In response to the COVID-19 pandemic, the Families First Coronavirus Response Act (FFCRA) mandated that state Medicaid agencies had to maintain continuous Medicaid and CHIP enrollment from March 2020 to qualify for temporary Federal Medical Assistance Percentage (FMAP) increases.37“Families First Coronavirus Response Act”, H.R.6201, 116th Cong., enacted March 18, 2020, accessed May 1, 2025. https://www.congress.gov/bill/116th-congress/house-bill/6201/text This resulted in large increases in Medicaid enrollment through the delinking of FMAP from continuous enrollment in April 2023. However, even with increased enrollment, drug spending per Medicaid enrollee increased by 7.3% from 2019 to 2023, as shown in Table 2 below. This indicates that external market conditions were responsible for Medicaid spending growth.
Table 2. Medicaid Prescription Drug Expenditures per Enrollee38Medicaid.gov, “Medicaid Enrollment – New Adult Group”, Open Data, updated December 11, 2024, accessed May 1, 2025. https://data.medicaid.gov/dataset/6c114b2c-cb83-559b-832f-4d8b06d6c1b9/data , 39All dollar amounts are reported in 2023 real dollars. Centers for Medicare & Medicaid Services, “National Health Expenditure Data: Historical, NHE Tables,” “Table 04 National Health Expenditures by Source of Funds and Type of Expenditures,” updated December 18, 2024, accessed April 22, 2025, https://www.cms.gov/data-research/statistics-trends-and-reports/national-health-expenditure-data/historical,40Centers for Medicare & Medicaid Services, “Quick Definitions for National Health Expenditure Accounts (NHEA) Categories”, accessed April 24, 2025. https://www.cms.gov/files/document/quick-definitions-national-health-expenditures-accounts-nhea-categories.pdf
| Year41All dollar amounts are in 2023 real dollars. | Medicaid Total Enrollment42Enrollment numbers are based on Q4 total enrollment as reported by Medicaid.gov. | Prescription Drug Expenditures43 The “Prescription Drugs” category Covers the “retail” sales of human-use dosage-form drugs, biological drugs, and diagnostic products that are available only by a prescription. | Drug Expenditures per Enrollee |
| 2019 | 74.62 million | $37.8 billion | $507 |
| 2023 | 93.79 million | $51 billion | $544 |
| % Change | 25.7% | 34.8% | 7.3% |
The Path Forward
President Trump’s April 15 Executive Order aimed at lowering drug prices and multiple active legal battles between the government and pharmacy benefit managers clearly indicate that now is the time to capitalize on momentum to address problems in the prescription drug industry. Many industry experts have written recommendations on how to rein in prescription drug costs. We list several priority recommendations:
- Codify patient and pharmacy protections and price transparency: Bi-partisan Senate Bill 927 “Protecting Pharmacies in Medicaid Act” aims to level the negotiating playing field across all 50 states by eliminating spread pricing and requiring all participant pharmacies to submit National Average Drug Acquisition Cost surveys.
- Improve the Drug Price Negotiations Program: Responding to Executive Order 14273, modifications to the current Medicare Drug Price Negotiation Program should not delay lower prices for life-saving medications. Reducing the biologics exemption grace period to 9 years will bring it in line with small molecule drugs and eliminate the “pill penalty.” Furthermore, the negotiated Maximum Fair Prices from negotiations currently only apply to Medicare Part D. This means beneficiaries enrolled in Medicare Advantage (Part C) plans that include prescription drug coverage or in state Medicaid will not see the benefits of these drug negotiations. Expanding price negotiations to Medicare Part C and Medicaid can help the government to rein in prescription drug costs while maintaining robust prescription drug coverage through existing MDRP agreements.
- Expand standards on formulary design to steer access to lower cost prescription drugs: The most recent proposed rule for CY 2026 included a formulary design requirement with “broad access” to generics and biosimilars for Part D coverage.44Centers for Medicare & Medicaid Services, “Medicare and Medicaid Programs; Contract Year 2026 Policy and Technical Changes to the Medicare Advantage Program, Medicare Prescription Drug Benefit Program, Medicare Cost Plan Program, and Programs of All-Inclusive Care for the Elderly”, Federal Register, December 10, 2025, accessed April 30, 2025. https://www.federalregister.gov/documents/2024/12/10/2024-27939/medicare-and-medicaid-programs-contract-year-2026-policy-and-technical-changes-to-the-medicare Expanding formulary design and tying rules to Part C and state Medicaid program funding will increase the number of Americans whose drug benefits will be improved by such rules.
- Reform PBM rebate and pricing models: The strong linkage between manufacturer rebates and drug list prices creates market incentives to increase the price of prescription drugs. Renegotiating rebates with drug manufacturers as service fees that reflect the value of the services PBMs provide will sever the tie between rebates and the price of the drug the manufacturer produces. There is also a lack of transparency in PBM claim value calculations. Publishing PBM calculation methodology for prescription drug claim value to increase market price predictability and improve business transparency.
As a part of Rios Partners’ continued engagement on this topic, we are soliciting perspectives from industry leaders to continue to expose the depth of concern of this topic. If you’d like to share your perspective, email us at healthofhealth@riospartners.com.