Drug pricing policy is no longer evolving gradually but is instead shifting in real time, with immediate consequences for manufacturer strategy, payer behavior, and patient access.

At the Asembia AXS26 Summit in Las Vegas, Dee Chaudhary, BA, MBA, principal, Commercial Strategy Consulting Life Sciences and Healthcare, Clarivate, outlined how converging policy forces such as the Inflation Reduction Act (IRA), Most Favored Nation (MFN) pricing, passage of the One Big, Beautiful Bill Act (OBBBA), emerging international reference pricing pressures, and new federal legislation are accelerating change across the pharmaceutical landscape.

“We’re entering a phase where policy design is translating directly into payer behavior,” Chaudhary said. “All of the things that used to move slowly and in isolation…are now moving fast and in parallel.”

How is IRA implementation actively reshaping payer behavior?

A central theme of Chaudhary’s session was the shift from policy design to real-world execution under the IRA. According to Chaudhary, the law’s pricing provisions are no longer theoretical, they are now embedded in payer decision-making and market dynamics.

“This is where the IRA stops being policy theory and becomes real-world math for manufacturers,” she said. “Everything is already live. It’s already operational. It’s already reshaping payer behavior.”

With the first round of Medicare negotiated prices taking effect in January 2026, and additional cycles already in motion, payers and pharmacy benefit managers (PBMs) are beginning to anchor their expectations to these benchmarks.

“These are not symbolic cuts,” Chaudhary said. “They’re part of payer contracting conversations, and PBMs are starting to treat these as de facto reference points and in some manner, a commercial floor.”

That shift is having a direct impact on pricing power, access strategies, and long-term asset value, particularly as negotiated prices begin to influence markets beyond Medicare.

Why are payers accelerating utilization management?

During her presentation, Chaudhary also noted that as financial risk shifts more heavily onto plans, payer behavior is evolving faster and more aggressively than many manufacturers anticipated.

“What we’re seeing now is that payer utilization management is intensifying faster, it’s more than the policy language ever really implied,” she said.

Across Medicare Advantage and Part D plans, this is expected to translate into tighter formularies, increased use of prior authorizations and step edits, and a broader move toward “friction-based management.”

“Payers have moved really decisively from broad access to friction-based management,” Chaudhary said. “There is no assumption of a clean access window anymore.”

These dynamics are especially pronounced with high-cost specialty drugs, for which plans face the greatest financial exposure. In response, some payers have gone as far as discontinuing legacy plan offerings and replacing them with more restrictive designs to better control costs.

“This is all, first and foremost, going to hit high-cost specialty drugs,” she noted, pointing to oncology, immunology, and other high-spend categories as key pressure points.

How is policy-driven instability increasing market volatility?

Beyond the IRA, Chaudhary’s discussion highlighted the growing impact of broader federal policy changes, particularly the OBBBA, in driving instability across coverage and reimbursement.

“The OBBBA doesn’t just rewrite drug policy, it really raises the temperature,” she said, noting that changes to Medicaid eligibility, marketplace verification, and affordability structures are contributing to increased coverage churn, with patients cycling on and off plans more frequently.

This is expected to have downstream consequences for adherence, access, and manufacturer forecasting.

“What’s the result? Greater coverage churn, affordability risk, and the payers are already responding,” Chaudhary explained. “It makes forecasting now a moving target.”

Chaudhary also pointed to Medicare Part A solvency concerns as an underrecognized factor that could further intensify pricing pressure, saying, “When the trust fund looks weaker and it looks weaker sooner, Congress looks for fast, high-yield offsets, and drug pricing is always the most visible and easy-to-access lever.”

Taken together, these forces are creating a more volatile operating environment, one in which access is less predictable and cost containment efforts are likely to accelerate.

How are global pricing pressures and MFN models tightening the pricing corridor?

In her session, Chaudhary also underscored the re-emergence of MFN pricing as a significant long-term risk, particularly as policymakers and payers look beyond domestic benchmarks.

“MFN is not a negotiation. It’s not a rebate discussion,” she said. “It’s a global price benchmark and the U.S. market is being pulled down toward it.”

While initially tied to government programs, MFN-style pricing is expected to influence commercial markets, with PBMs potentially using international reference points in contracting decisions. This creates a narrowing “pricing corridor” for manufacturers, where both high and low pricing strategies carry trade-offs.

“Launch low…and you end up with an MFN tail risk,” Chaudhary said. “Launch high, and the payers are going to use that as a justification for earlier and harsher utilization management.”

As a result, pricing and launch sequencing decisions are becoming more interconnected across global markets.

“There’s no longer a world where we have this clean six- to 12-month access runway,” she added. “You are launching directly into friction, leakage, and early pressure.”

How to adapt strategy to a faster-moving pricing environment?

Chaudhary concluded her session by emphasizing that manufacturers must take a more proactive and integrated approach to navigating this evolving landscape as policy changes continue to unfold.

“If you’re not looking at this every day there can be big strategies that are ready to go forward that you have not adjusted for,” she said. That includes reassessing value frameworks, modeling new pricing scenarios, and aligning global and domestic strategies earlier in the product lifecycle.

While the environment is becoming more complex, Chaudhary framed it as a call for adaptation rather than alarm.

“I’m not going to be Chicken Little here and tell you the sky is falling, but you want to look forward and not just settle into what you’re comfortable with,” said Chaudhary.