Cubanski: From a practical standpoint, the Most Favored Nation model that was initiated by the Trump Administration is not likely to have any impact in the near term, since a district court issued a preliminary injunction temporarily blocking HHS from implementing the model, and the CMS Innovation Center has stated that it will not move forward with the model without further rulemaking. But as for the bigger picture, if one of the motivating factors behind biosimilar development is bringing lower-cost versions of high-priced biologics to market, steps taken to lower prices of the originator biologics could dampen enthusiasm for biosimilar entry. On the other hand, policy actions taken to lower prices of biologics would generate savings for payers and patients, just as would bringing biosimilars to market.
Muñoz: One of the most significant issues to consider is that the financial incentives for biosimilar stakeholders are reduced if the spread between originator and biosimilar prices is narrower. In analyzing the current biosimilar pipeline, there appears to be a financial threshold, such that originator products with lower sales are not attracting biosimilar developers. Increasing this pricing pressure may reduce the number of products with a feasible market, potentially diminishing biosimilar development. The biosimilars available are for patients who are not necessarily financially motivated – they are often hitting out-of-pocket maximums. Payer motivation is based on a better negotiation amount, and the pressure from MFN or a policy like it could effectively limit the biosimilar market.
Traxel: I do not believe that this Executive Order will go into effect but if it did, I think it could potentially deter manufacturers from developing biosimilars. Under this proposal, biosimilars would be subjected to international reference pricing and it could narrow the differential in prices between originators and biosimilars.