WASHINGTON, March 24, 2026 /PRNewswire/ -- The Rare Access Action Project (RAAP) today announced the release of a new policy paper, "Importing Most Favored Nation Pricing into States Is Not the Answer," examining the growing interest among states in applying international reference pricing models to prescription drug affordability policies. The study concludes that importing Most Favored Nation (MFN) pricing benchmarks into state Prescription Drug Affordability Board (PDAB) frameworks could unintentionally jeopardize patient access while failing to address the root causes of affordability challenges.

As states continue to seek solutions to rising prescription drug costs, many have turned to PDABs, to review high-cost therapies and, in some cases, set Upper Payment Limits (UPLs) on reimbursement. While intended as a policy that would reduce the cost of prescriptions, the study finds that combining PDAB authority with MFN-style pricing benchmarks creates structural and operational risks within the U.S. healthcare system.

The analysis explains that MFN pricing, tying U.S. reimbursement levels to the lowest prices paid in other countries, does not translate effectively to state-level policy because international prices reflect fundamentally different healthcare systems, including centralized purchasing, restricted formularies, and access limitations that are not in the United States.

"States are right to focus on affordability, but policy solutions must work within the realities of how care is delivered," said Michael Eging, Executive Director of the RAAP. "Our research shows that importing MFN pricing into state reimbursement policy risks creating supply disruptions, administrative barriers, and delayed treatment, especially for patients with rare diseases who already face limited options. Affordability reforms should lower patient costs without destabilizing access to lifesaving therapies."

RAAP's newest study highlights several key findings:

• Operational mismatch: MFN benchmarks often bear little relationship to U.S. drug acquisition and delivery costs. When reimbursement ceilings fall below those costs, pharmacies and providers may stop stocking or administering affected therapies.
• Supply chain consequences: Payment caps tied to foreign prices can trigger changes in distributor contracts, provider participation, and site-of-care availability, leading to treatment delays or interruptions.
• Federal policy conflicts: MFN-driven payment limits may interact with the Medicaid Drug Rebate Program's "best price" rules, potentially creating nationwide pricing implications stemming from a single state policy.
• Disproportionate impact on rare disease patients: Limited distribution networks, specialized treatment centers, and the absence of therapeutic alternatives make rare disease access particularly sensitive to reimbursement disruptions.

The study, researched and written by Jennifer Snow of Apteka stated, "MFN pricing answers the question of what the lowest observed price is elsewhere, not what reimbursement level is sustainable within the U.S. healthcare system. When foreign price benchmarks are applied without accounting for distribution economics, care delivery costs, and federal rebate rules, the result can be instability to access rather than affordability gains."

Rather than adopting MFN-based reimbursement caps, the study recommends that states pursue affordability strategies directly tied to patient costs, including benefit design reforms that reduce out-of-pocket expenses, transparency improvements, high-cost risk pooling for rare diseases, and access safeguards if PDAB policies move forward.

"Policy success should ultimately be measured by whether patients can reliably access the treatments they need," Eging added. "States have an opportunity to pursue affordability solutions that strengthen, not weaken, the systems patients depend on."

The full report, "Importing Most Favored Nation Pricing into States Is Not the Answer," is available at: https://www.rareaccessactionproject.org/state-policies/mfn/importing-most-favored-nation-pricing-into-states-is-not-the-answer/

RAAP, the Rare Access Action Project, is a coalition of patient and life sciences stakeholders that explore creative policy solutions to address structural issues in access and coverage. Our priority is to help ensure rare disease patients have access to the care and treatments they need. 

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SOURCE Rare Access Action Project (RAAP)