On August 27, 2026, the Northern Virginia Health Policy Forum hosted a discussion on the global implications of the United States’ adoption of Most Favored Nation (MFN) drug pricing. Moderated by Jim Scott, President and CEO of Applied Policy, the conversation featured Dr. Stefan Walzer, CEO, President, and Founder of MArS Market Access & Pricing Strategy GmbH, and Brittany La Couture, Vice President of Health Policy at Applied Policy and a former member of the Centers for Medicare & Medicaid Services’ Center for Medicare and Medicaid Innovation (CMMI) team that worked on the International Pricing Index (IPI) model during the first Trump administration.
Scott, Walzer, and La Couture discussed the potential impacts of CMMI’s GENErating cost Reductions fOr U.S. Medicaid (GENEROUS), and the proposed Global Benchmark for Efficient Drug Pricing (GLOBE) and Guarding U.S. Medicare Against Rising Drug Costs (GUARD) models. Noting that details of GLOBE and GUARD have yet to be finalized, the panelists considered how international reference pricing could affect pharmaceutical pricing, launch strategies, patient access, and investment in research and development in the United States and abroad.
Scott opened by asking about the differences between the U.S. market and European pharmaceutical markets. La Couture noted that drug manufacturers have historically been able to set prices in the U.S. market independent of pricing elsewhere. Walzer observed that, in contrast, Europe has long been an interconnected pricing environment in which the price negotiated in one country can directly influence prices a manufacturer charges in other countries. Policies in the new CMMI models would link U.S. and European markets.
La Couture traced the current U.S. approach to President Trump’s May 2025 executive order on MFN drug pricing and described an administration strategy that extends beyond CMMI models to direct-to-consumer purchasing and international trade policy. She explained that GLOBE and GUARD would apply to Medicare Part B and Part D drugs, respectively, using international benchmarks to determine manufacturer rebate obligations. When Scott asked how pharmacies and Part D plans could be sure of acquiring drugs at the benchmarked rate, La Couture replied they could not: providers and pharmacies may still pay higher prices while manufacturers separately pay rebates to CMS.
Potential effects on pricing, launches, and investment
When Scott asked whether international reference pricing would necessarily lower pharmaceutical prices, Walzer expressed skepticism. He observed that manufacturers might respond by seeking higher prices outside the United States, though he cautioned that the substantial difference between U.S. and European prices would make closing that gap difficult. He added that the policies could also affect where and when manufacturers launch new products: if a comparatively low price in one country can reduce reimbursement in the much larger U.S. market, manufacturers may have stronger incentives to delay or reconsider launches in lower-priced markets.
La Couture noted that Applied Policy’s review of manufacturer comments in response to GLOBE and GUARD found recurring concerns about patient access, R&D investment, and the operational complexity of international benchmarks. She said manufacturers’ response to the models might include changes to pricing and launch decisions, such as indication splitting, launching only the highest-cost indications first. Walzer observed that international pricing and evidence requirements may need to be considered much earlier in product development.
Intersection with larger trade policy
The panel considered the intersection of drug pricing and trade policy, beginning with a recent U.S.–U.K. pricing agreement under which the United Kingdom agreed to spend more on new medicines and raise its NICE cost-effectiveness threshold, while the United States agreed not to impose new tariffs on U.K. pharmaceutical and medical exports through 2029. Walzer doubted the deal would meaningfully lift pharmaceutical spending or access soon, and noted manufacturers are already invoking it to press other European governments. He and La Couture pointed to the U.S. Trade Representative’s Section 301 investigation of Germany’s drug pricing as a related lever. La Couture said it reflects the administration’s view that German price controls push brand prices below fair market value, leaving U.S. patients paying far more. Walzer read it as a negotiation push toward a broader U.S.–German agreement rather than a punitive measure. He also noted Germany’s continued appeal as an early-launch market, where new drugs reach patients while price negotiations proceed.
Uncertainty, complexity, and what comes next
When asked for her final takeaway, La Couture returned to themes she had raised throughout the conversation: uncertainty and complexity. She stressed that much remains unsettled, with the details of GLOBE and GUARD not yet finalized . She framed that uncertainty as an opportunity for manufacturers willing to treat domestic and international strategy as a unified whole. Walzer emphasized that MFN is not merely a U.S. pricing policy but a global one, requiring manufacturers to plan launch and evidence strategy early. Both underscored a consideration for manufacturers and policymakers alike: U.S. pharmaceutical policy can no longer be viewed independently of pricing, reimbursement, access, and launch decisions elsewhere in the world.
Scott, Walzer, and La Couture will continue the conversation over the coming months as they present a paper at King’s College London in October. In addition, Applied Policy and MArS will host a reception during ISPOR Europe in Vienna in November, where Applied Policy will also present a poster.
Watch a recording of the event below.
