The Next Wave Of Reforms That Will Hit Drug Access Hardest

Drug Access Reform: The Next Wave of Policies That Could Reshape Medicine Access

Drug-access reform is the set of public policies, market rules, and payment changes that determine whether patients can obtain medicines at an affordable cost and without unreasonable delay. The reforms most likely to create the sharpest near-term access pressure are Medicare price negotiation and redesigned benefit costs, tighter scrutiny of pharmacy-benefit managers, Medicaid and 340B payment changes, stricter evidence requirements for accelerated approvals, and international measures that limit launch prices or national medicine spending. These policies may reduce prices for some established products, but they can also alter formularies, delay launches, reduce manufacturer revenue, and make coverage harder to secure for high-cost or clinically uncertain therapies. The Congressional Budget Office projects that Medicare’s first negotiated prices will reduce federal spending, while the FDA reports that more than 300 products have reached patients through the accelerated-approval pathway since its creation—illustrating why changes to both pricing and evidence rules matter for access.

Drug Access Reform Defines Who Pays, What Gets Covered, and When

Drug access reform can be defined as an intervention that changes the price, eligibility, evidence, distribution, reimbursement, or utilization rules governing medicines. The World Health Organization describes access to medicines through dimensions that include availability, affordability, appropriate selection, and reliable health-system delivery. In practical terms, the entity is “drug access,” while the attribute “reform” describes a deliberate change to the rules that shape that access.

The most important characteristic of the current reform wave is that it is moving beyond simple list-price regulation. Policymakers are targeting the entire access chain: manufacturer pricing, insurer negotiations, pharmacy-benefit-manager contracts, prior authorization, specialty-pharmacy distribution, government rebates, clinical evidence, and patient out-of-pocket exposure. IQVIA estimates that global medicine spending will continue rising through the end of the decade, even as payers demand stronger evidence of value and seek larger discounts.

Affordability Reform Targets Prices and Patient Liability

Affordability reform consists of measures intended to lower the amount paid by governments, insurers, or patients. Examples include negotiated prices, inflation rebates, annual out-of-pocket limits, copay smoothing, generic substitution, biosimilar competition, and restrictions on manufacturer price increases.

The United States Inflation Reduction Act is the clearest example. Medicare Part D out-of-pocket spending is capped at $2,000 in 2025, and beneficiaries may spread eligible costs across monthly payments. The law also permits Medicare to negotiate prices for selected high-spending drugs. CMS selected 10 medicines for the first negotiation cycle, with negotiated prices taking effect in 2026, followed by 15 additional drugs in 2027 and at least 30 drugs annually from 2028 onward.

These provisions should improve affordability for many beneficiaries using expensive medicines, but the access effects will not be uniform. A lower negotiated price may expand use of a selected drug, while a plan could respond through preferred-product placement, tighter utilization management, or greater reliance on a competing therapy. The Congressional Budget Office estimates that negotiation will reduce federal deficits, but its analyses also indicate that reduced expected revenue can modestly lower future drug development.

Coverage Reform Determines Whether a Prescription Is Functionally Available

Coverage reform changes the conditions under which an insurer or public program pays for a medicine. Formularies, tier placement, step therapy, prior authorization, quantity limits, and specialty-pharmacy requirements are all hyponyms of coverage reform. A medicine can be approved and physically available yet remain practically inaccessible if a patient cannot satisfy these conditions.

KFF has documented the growing importance of high-cost specialty medicines in Medicare and commercial insurance. These products often require complex administration, monitoring, or clinical documentation, giving payers strong incentives to manage utilization. The resulting friction is most severe for patients with rare diseases, unstable insurance coverage, or conditions for which treatment guidelines are still evolving.

The bridge from affordability to coverage is therefore critical: when reforms reduce the price paid by a plan, they may improve formulary access, but when reforms increase evidentiary or administrative requirements, they may create new delays. The next wave will be judged not only by average prices but also by approval-to-treatment time and the share of prescribed patients who actually start therapy.

Medicare Negotiation Creates the Most Immediate Commercial Pressure

Medicare negotiation is a purchasing reform that allows the federal government to establish a maximum fair price for selected high-spend medicines after negotiations with manufacturers. The first group includes widely used products such as Eliquis, Jardiance, Xarelto, Januvia, Farxiga, and Entresto. CMS said the negotiated prices for the first 10 drugs represent discounts ranging from approximately 38% to 79% compared with list prices, depending on the product and comparison method.

Established Blockbusters Face the Strongest Direct Exposure

The direct impact is greatest for mature, high-revenue medicines that meet statutory eligibility rules and have limited generic or biosimilar competition. Manufacturers of these products may accept lower Medicare revenue, offer larger rebates, alter launch sequencing, or redirect investment toward products less exposed to negotiation.

The access benefit is clearest for Medicare patients who previously faced high coinsurance. However, a negotiated price does not automatically eliminate nonprice barriers. Insurers may still use prior authorization, and patients may encounter shortages, changes in dispensing channels, or confusion during formulary transitions. CMS implementation guidance and beneficiary experience will determine whether the statutory savings translate into reliable treatment access.

Small-Molecule Timing Can Distort Launch and Competition Decisions

Under current law, small-molecule medicines generally become eligible for negotiation earlier than biologics because of different eligibility timelines. This distinction may influence whether companies prioritize a small-molecule launch, invest in follow-on indications, or favor biologic platforms with longer periods before negotiation eligibility.

The policy issue is not simply whether a medicine becomes cheaper. It is whether the timing rule changes the mix of future products, the willingness to pursue incremental indications, or the business case for treatments serving small patient populations. The National Pharmaceutical Council and Congressional Budget Office have both emphasized that the long-run effects depend on how manufacturers adjust research portfolios, not only on the immediate price reduction.

Pharmacy-Benefit-Manager Reform Redirects Access Through the Supply Chain

Pharmacy-benefit-manager reform targets intermediaries that negotiate rebates, design formularies, manage pharmacy networks, and process prescription claims. The Federal Trade Commission has described the sector as highly concentrated and has investigated the business practices of major PBMs, including rebate arrangements, specialty-pharmacy ownership, and methods of determining pharmacy reimbursement.

Rebate Disclosure and Compensation Rules Could Change Formulary Incentives

A central reform proposal is to require greater transparency or to replace percentage-based compensation with fixed fees. The policy rationale is that rebates tied to list prices can reward higher-priced products, even when the net price after discounts is lower. Reformers argue that passing savings directly to plans or patients could reduce out-of-pocket costs.

The access risk is transitional complexity. If rebates are removed or redesigned without changing benefit structures, premiums could rise, formularies could narrow, or costs could shift from employers and insurers to patients at the pharmacy counter. The FTC’s interim findings have intensified scrutiny, but the final effect will depend on contract design, competition, and whether savings are passed through to the people filling prescriptions.

Specialty-Pharmacy Control Can Create Concentration at the Point of Dispensing

Specialty-pharmacy reform addresses the use of restricted networks and affiliated dispensing operations for complex medicines. These arrangements can coordinate clinical support and reduce waste, but they may also limit patient choice and create conflicts when the same corporate group influences coverage, authorization, and dispensing.

This issue matters most for oncology, autoimmune, rare-disease, and gene therapies, where a treatment may cost tens of thousands of dollars per course or require clinical monitoring. Policymakers seeking lower prices must therefore measure access through more than average spending: network adequacy, abandoned prescriptions, time to dispense, and successful therapy initiation are equally important indicators.

Evidence Reform May Hit Innovative and High-Uncertainty Medicines Hardest

Evidence reform changes the clinical proof required for approval, reimbursement, or continued market access. It includes accelerated-approval rules, confirmatory-trial deadlines, comparative-effectiveness requirements, real-world-evidence standards, and payer demands for outcomes-based contracts.

Accelerated-Approval Reform Raises the Bar After Early Access

The FDA’s accelerated-approval pathway permits certain medicines for serious conditions to reach patients using surrogate endpoints that are reasonably likely to predict clinical benefit. Sponsors must then conduct confirmatory studies. FDA data show that hundreds of products have used the pathway, particularly in oncology, infectious disease, and rare diseases.

Recent reforms give the FDA stronger authority to require timely confirmatory trials, modify or withdraw approvals when evidence fails, and address products whose post-approval studies are delayed. These changes can protect patients from ineffective treatments and reduce spending on medicines that do not confirm benefit. Yet they may also hit rare-disease therapies hardest because patient populations are small, endpoints are difficult to validate, and randomized trials can be slow or infeasible.

Real-World Evidence Can Expand Access or Add Another Gate

Real-world evidence uses data from electronic health records, registries, insurance claims, and routine clinical practice to evaluate safety and effectiveness. FDA guidance recognizes that such evidence can supplement traditional trials, especially for rare conditions and long-term outcomes.

The benefit is flexibility: regulators and payers may learn from actual treatment populations rather than waiting for perfect trial data. The risk is inconsistent data quality. If insurers demand highly specific outcomes evidence before covering a medicine, therapies may face a second approval process after regulatory approval. That could delay access for patients who have no good alternatives.

Medicaid, 340B, and State Importation Rules Could Shift Distributional Effects

Medicaid and 340B reforms affect medicines supplied to low-income patients, safety-net providers, and public hospitals. Medicaid’s rebate structure already requires manufacturers to provide statutory discounts, while the 340B program enables eligible organizations to purchase outpatient medicines at reduced prices. Reform proposals focus on rebate calculations, duplicate discounts, contract pharmacies, site eligibility, and manufacturer obligations.

Medicaid Rebate Changes Could Improve Budgets but Narrow Product Participation

Medicaid drug rebates reduce program spending and help states cover medicines for more than 80 million Americans, according to CMS enrollment data. However, changes to rebate formulas or coverage obligations can alter manufacturer participation incentives. If a product becomes less profitable in Medicaid, access could be affected through restrictions, delayed contracting, or reduced promotional support, although federal law limits the ability to exclude medicines in many circumstances.

340B Oversight Will Test the Balance Between Provider Revenue and Patient Benefit

The 340B program is intended to help eligible hospitals and clinics stretch scarce federal resources. The Health Resources and Services Administration has expanded oversight as disputes have grown over contract pharmacies, manufacturer shipment limits, and how savings are used.

Tighter controls could improve accountability and ensure that discounts support safety-net care. But if manufacturers restrict distribution or providers lose expected savings, rural hospitals, community health centers, and specialty clinics could face financial pressure. The practical access question is whether reform protects the medicine supply for vulnerable patients while preventing discounts from becoming disconnected from patient assistance.

International Pricing Reform Will Pressure Launches and Global Availability

International pricing reform includes health-technology assessment, external reference pricing, centralized procurement, national spending caps, and agreements that link reimbursement to comparative clinical value. These measures are particularly influential in Europe, where national health systems negotiate coverage and price more directly than most United States insurers.

Health-Technology Assessment Makes Comparative Value a Coverage Requirement

Health-technology assessment evaluates a medicine’s clinical effectiveness, safety, cost-effectiveness, budget impact, and sometimes broader social value. The European Union’s new health-technology-assessment framework begins applying to certain medicines in 2025 and expands over time. Its purpose is to reduce duplicated assessments and strengthen joint clinical evaluations across member states.

For manufacturers, the reform creates a stronger need to generate comparative evidence at launch. For patients, it may improve consistency and reduce delays between countries. The risk is that products with uncertain benefits, narrow indications, or high prices may receive restricted coverage or launch later in smaller markets.

Revenue Agreements Can Lower National Spending While Affecting Availability

The United Kingdom’s voluntary scheme for branded medicines and pricing access regulates the growth of branded-medicine spending through an industry-wide payment mechanism. The 2024–2028 agreement includes a permitted growth rate and manufacturer payments when spending exceeds the agreed limit.

Such agreements can make national budgets more predictable, but they may influence launch order, discount expectations, and investment in medicines with limited commercial markets. A global company may prioritize countries where reimbursement decisions are faster or prices are less visible internationally. This creates a tension between national affordability and timely global availability.

The Hardest-Hit Access Points Are Specialty Care, Rare Disease, and New Launches

The burden of reform will not fall evenly across the medicine market. Generic drugs with multiple suppliers are generally better positioned to absorb price competition. The greatest vulnerability lies in medicines with high research costs, small patient populations, complex administration, uncertain long-term evidence, or limited therapeutic substitutes.

  • Rare-disease treatments may face stronger evidence demands even when conventional trials are difficult.
  • Cell and gene therapies may encounter payment limits because one-time prices are high while long-term benefits remain uncertain.
  • New oncology medicines may face comparative-effectiveness reviews before their full benefit is understood.
  • Specialty biologics may be exposed to biosimilar substitution, rebate restructuring, and narrower distribution networks at the same time.
  • Small biotechnology companies may have less negotiating power and fewer resources to conduct post-approval studies or manage complex payer contracts.

A useful dashboard for policymakers should therefore track more than drug spending. It should include median time from approval to coverage, prior-authorization approval rates, prescription abandonment, treatment initiation, shortages, launch delays by country, clinical-trial investment, and the number of patients receiving therapies through assistance programs.

Chart suggestion: a four-line chart could compare list-price growth, net-price growth, patient out-of-pocket spending, and new-product launches from 2015 through 2028. A second chart could map each reform against its likely effect on affordability, evidence burden, manufacturer incentives, and treatment availability.

How Policymakers Can Reduce Prices Without Creating New Access Barriers

The strongest reforms will pair price intervention with access safeguards. Negotiated prices should be monitored for formulary restrictions and treatment delays. PBM reforms should specify how savings reach patients rather than assuming that lower plan costs automatically reduce point-of-sale spending. Evidence rules should permit adaptive designs, registries, and pragmatic trials for rare diseases while enforcing credible deadlines for confirmatory studies.

  1. Publish standardized measures of time to treatment, prescription abandonment, and coverage denials.
  2. Require transparent explanations when a lower-cost medicine is not placed on a preferred formulary tier.
  3. Protect access to medically necessary therapies during formulary and negotiated-price transitions.
  4. Use outcomes-based payment models for high-cost one-time treatments, with clear data standards and patient protections.
  5. Evaluate reforms by income, race, geography, disability, disease severity, and insurance type.
  6. Preserve incentives for generic, biosimilar, antibiotic, and rare-disease development while preventing unjustified market exclusivity.

Conclusion: Drug Access Reform Must Measure Treatment, Not Just Price

Drug access reform is entering a more consequential phase. Medicare negotiation and benefit redesign will put immediate pressure on high-spend products; PBM rules may change how rebates and formularies shape patient costs; accelerated-approval and real-world-evidence reforms will raise expectations for clinical proof; and international health-technology assessment will make comparative value more important at launch. Medicaid and 340B changes will determine how savings and obligations are distributed among manufacturers, public programs, hospitals, and vulnerable patients.

The reforms most likely to hit access hardest are those that combine lower prices with greater uncertainty about coverage, evidence, or distribution. Lower spending is an important objective, but it is not the same as successful access. Regulators, payers, manufacturers, clinicians, and patient groups should track whether reforms shorten the path from prescription to treatment and whether they preserve innovation for rare, complex, and underserved conditions. Further reading should begin with CMS implementation documents, Congressional Budget Office analyses, FDA accelerated-approval guidance, FTC PBM investigations, WHO access frameworks, and independent KFF evaluations of patient costs.

Sources: World Health Organization, Access to Medicines and Health Products, https://www.who.int/teams/health-product-and-policy-standards/access-to-medicines-and-health-products; Centers for Medicare & Medicaid Services, Medicare Drug Price Negotiation Program, https://www.cms.gov/inflation-reduction-act-and-medicare/medicare-drug-price-negotiation; Congressional Budget Office, Prescription Drug Price Negotiation Under the Inflation Reduction Act, https://www.cbo.gov/topics/health-care/prescription-drugs; Centers for Medicare & Medicaid Services, Medicare Part D Improvements Under the Inflation Reduction Act, https://www.cms.gov/inflation-reduction-act-and-medicare/part-d-improvements; U.S. Food and Drug Administration, Accelerated Approval Program, https://www.fda.gov/drugs/resources-information-approved-drugs/accelerated-approval-program; U.S. Federal Trade Commission, Pharmacy Benefit Managers, https://www.ftc.gov/news-events/topics/competition-enforcement/competition-matters/pharmacy-benefit-managers; Kaiser Family Foundation, Prescription Drugs, https://www.kff.org/prescription-drugs/; Health Resources and Services Administration, 340B Drug Pricing Program, https://www.hrsa.gov/opa; European Commission, Health Technology Assessment Regulation, https://health.ec.europa.eu/health-technology-assessment/overview_en; UK Department of Health and Social Care, Voluntary Scheme for Branded Medicines Pricing and Access, https://www.gov.uk/government/publications/voluntary-scheme-for-branded-medicines-pricing-and-access-2024; IQVIA Institute for Human Data Science, The Global Use of Medicines Outlook, https://www.iqvia.com/insights/the-iqvia-institute/reports-and-publications/reports/the-global-use-of-medicines-outlook