AbbVie, MFN, and a World of Ambiguity

On January 12, AbbVie announced that it had reached an agreement with the Trump administration on participation in its most favored nation (MFN) pricing initiative, and making certain medications available through its direct-to-consumer platform.

With the various agreements made with 15 other pharmaceutical companies, specific drugs were not disclosed. This is the first time in the short history of the MFN initiative that it involves a reference product with active biosimilar competition—that is, of publicly disclosed information.

However, the MFN (and Medicare maximum fair price for that matter) programs were explicit in their intent to avoid interfering with the biosimilar and generic marketplaces. For their part, AbbVie may simply be seeking another access channel to forestall fading Humira volume. It is not expected that the TrumpRx direct-to-consumer channel would be particularly strong.

What Is the MFN Price of Humira Likely to Be?

What would be the MFN price of Humira? Data on which the calculation derived from the administration’s international pricing index of countries with comparable economies are a bit dated, and the source has not been verified. Based on 2023 prices, Humira pricing ranges from $875 per 40 mg dose in Italy to $316 in France (of countries included in the MFN international index). Many of the adalimumab biosimilars are already providing deep discounts (some greater than 85%), to a price range of $450 to $693 for the same dose. At least one biosimilar is available through Mark Cuban’s Cost Plus at a 92% discount. What AbbVie offers under TrumpRx is unknown, but for cash paying buyers, Humira monthly cost will likely be hundreds of dollars, and largely unaffordable for most.

The point is that the biosimilar industry needs no additional impediment to its success, and most certainly, not in the adalimumab category. The reference product still retains the largest market share, and several adalimumab biosimilar makers are hanging on with miniscule volume.

In its rush to make TrumpRx MFN deals, the administration seems to have run roughshod over its own stated intention, to protect the biosimilar segment from harm. Simply, did AbbVie seek to include Humira in the arrangement, and the administration paid inadequate attention? Or did the administration seek to include Humira because of its boldface status, which would have been even stranger?

A Lack of Foresight or Lack of Principles?

Either way, this move sends a signal that the administration is conflicted about signing MFN deals for other reference drugs with active biosimilar competition. This isn’t an unintended consequence of the MFN policy; it’s a self-inflicted wound.

My original worry was that MFN, like Medicare’s maximum fair price negotiations, will discourage investment in biosimilar development. This was a problem for prospective biosimilar developers, I thought, not those with existing, approved biosimilars.

This seeming misstep is likely the result of the same “move fast and break things” mentality that has characterized this administration from the beginning of its second term. This was not a deeply considered move.

This article was written by our Director of Content, Stanton Mehr. Stan is has been writing commentary and reporting news about the biosimilar industry since the submission of the first biosimilar 351(k) application to the FDA 12 years ago. Since that time, BR&R has been tracking the US biosimilar marketplace, with the industry’s original, comprehensive and updated database of biosimilar filings with the FDA. 

Is There a Place for Private-Label Biosimilars Covered Under the Medical Benefit ?

Here’s a question that has been asked repeatedly over the last year or so: Does it make sense to have private label medical benefit-covered biosimilars?

We’ve seen the spread of private-label or “white-label” biosimilars, by the big 3 pharmacy benefit managers (PBMs) specifically, for adalimumab and ustekinumab. Although we’re not sure of current market utilization of the private-label versus non–private label products, we do know that the availability of the private-label products helped biosimilars on the road to uptake if not financial success.

We have in our sights some major medical benefit–covered reference products losing patent protection and marketing exclusivity over the next few years. These include Keytruda, Opdivo, Yervoy, Perjeta, and Ocrevus to name a few. All are high-cost agents that are important (if not critical) to patient care.

The discussion of a medical benefit private-label biosimilar must tease out the potential advantages/disadvantages for both the manufacturer and the provider (who in a buy-and-bill situation makes the initial prescribing decision) or payer (who decides on coverage/reimbursement). The first assumption is that PBMs generally deal far less with specialty drugs under the medical benefit (and especially oncology drugs). By their very name PBMs manage the pharmacy, not the medical, benefit. However, their affiliated specialty pharmacies are in a viable position to play an influential role, via white bagging. If that is the case, the provider’s buy-and-bill initiative would be lost, and they would be reimbursed solely for administration services. For PBMs, earning additional dollars through their specialty pharmacy, such white-labeled products seems highly promising.

The second assumption is that heavy competition at launch for medical benefit–covered biosimilars like Keytruda will result in huge, immediate net price discounts, as seen with the highly contested adalimumab and ustekinumab biosimilar launches. Competition is competition, regardless of how a drug is covered, so this is reasonable. The bigger question is whether Medicare price negotiation or most favored nations pricing hits before biosimilars launch (they shouldn’t, according to official and draft policy, but we should account for this anyway). A lower list price will mean lower cost savings for biosimilars.

A payer might be more neutral on the private-label issue. In general, private labels have not spelled greater net savings over low-WAC biosimilar versions of adalimumab or ustekinumab. They don’t seem to be extremely motivated to insist on non-private-label versus private-label biosimilar coverage. On the other hand, plan sponsors may think otherwise, based on the call for more PBM transparency. If the PD-1 inhibitor biosimilars, for instance, were available by private label through the specialty pharmacy, it would probably have little effect on payers except reducing buy-and-bill transactions for those specific products.

With the introduction of eight new Keytruda biosimilars competing for a $30 billion US market, discounts will quickly increase—regardless of MFP or MFN pricing. It should mean a virtual (delayed) free fall in average sales pricing (ASP), which will further dissuade providers from wanting to purchase these products and take on the risk of being caught underwater. If this follows, it drives purchases and distribution through the specialty pharmacy. Will the PBMs jump at the opportunity? Are there wholesaler or other relationships that they do not currently have to be in established first?

I don’t know the answers. I hope these thoughts spur a considered discussion of the advantages and disadvantages, and where this concept leads. Please lend your voice and comment on this topic.  

This article was written by our Director of Content, Stanton Mehr. Stan is has been writing commentary and reporting news about the biosimilar industry since the submission of the first biosimilar 351(k) application to the FDA 12 years ago. Since that time, BR&R has been tracking the US biosimilar marketplace, with the industry’s original, comprehensive and updated database of biosimilar filings with the FDA. 

The Next Set of Biologics for Medicare Price Negotiations Predicted (and Eliminated?)

With this first post since the holidays, there is so much to discuss, yet so little firm ground on which to anchor the discussion. Since December 23, the Trump administration has added two more drug pricing reform models to the gordian knot of US pharmaceutical reimbursement, and authors from the University of Washington School of Pharmacy have published their list of drugs anticipated to be subject to Medicare price negotiation for year 3.

In this article, we’ll unpack the latter first, because it is straightforward (sort of). Based solely on Medicare expenditures and market exclusivity expiration, the researchers published in the Journal of Managed Care and Specialty Pharmacy what they believe will be the next round of drugs to be subject to Medicare price negotiation this year, for implementation January 1, 2028. The Table below lists the following biologics (of 15 identified drugs in total).

TABLE: POTENTIAL BIOLOGICS FOR MEDICARE PRICE NEGOTIATION IN 2026 FOR 2028 IMPLEMENTATION

Reference Product Brand NameNonproprietary NameUS Biosimilar Candidates Publicly Disclosed?*Potential Launch of Biosimilars
TrulicityDulaglutidePossible†≥ 2030
OrenciaAbataceptYes (≥ 2)≥ 2028
EntyvioVedolizumabYes (≥3)≥ 2028
CosentyxSecukinumabYes (2)2027
XolairOmalizumabYes (≥5)2026
CimziaCertolizumabYes (≥1)2027
BotoxOnabotulinumtoxin APossible†N/A
SimponiGoliumumabYes (2)2026/2027
 
*Number of existing candidates indicated in parentheses. Some manufacturers have indicated work on several upcoming biosimilars, without specifying individual molecules. Therefore, the existence of undisclosed candidates must be considered. †One Chinese dulaglutide candidate identified, but may not be intended for US market. Previous Botox candidate was announced pre-2020, but no updated information exists. Sources: Cousin EM, Martin K, Hansen RN, et al. J Manag Care Spec Pharm. 2026;32(1):3-13; BR&R research.

This sunset of drugs represents the first time several biosimilar targets are included (as it is the first inclusion of part B drugs). Almost all drugs in the Table are covered to an extent under both part B and D. Indeed, the vast majority are currently the subject of biosimilar development. Some of these biosimilars will likely launch prior to 2028, before the negotiated Medicare price takes effect. Of course, predicted launch dates are dependent on patent settlements. The authors point out that other drugs are left off the list because their biosimilars are already marketed (e.g, aflibercept and denosumab) or eligibility is delayed by orphan drug rules (e.g., pembrolizumab and nivolumab, which will be eligible for selection in 2027).

If the Centers for Medicare and Medicaid Services (CMS) determine that a biosimilar launch is imminent, a request for delay in eligibility will be considered. However, CMS may seek negotiated prices if a request is not submitted, as occurred with ustekinumab. This will likely shrink the potential biosimilar revenues for these individual products. The reason CMS targets these products is that they are blockbusters. That is also the reason biosimilar manufacturers are interested in these biologics. With Medicare paying about one-third less for these agents in 2028 before biosimilar approval is obtained, they will be less interested in commercializing those agents. Consider the potential for limited market share (e.g., adalimumab), expensive patent litigation battles (e.g., nearly all products), and opportunity costs (i.e., against developing their own proprietary branded products).

Furthermore, if the ustekinumab experience is any reference, the negotiated Medicare Fair Price (MFP) will be well above the price that results from competition with several agents. The FDA is actively seeking to remove late-phase comparative trial requirements in an effort to lower development costs and reduce time to commercialization.

Today, it may make sense to modify CMS’s criteria for determining whether biosimilar launch is imminent. If a biosimilar product is already approved by FDA, this should take the reference product off the table for MFP eligibility. If three or more biosimilar products are actively in development (i.e., with FDA consultations or early-stage trials in progress) that should also eliminate the reference product from eligibility. I define three drugs as the threshold, because it should encourage significant price competition.

Drug payment and approval policies in this administration are moving all at once. We’ll review the latest salvo from CMS in the next post. However, with several biologics on the MFP list, the administration should review exactly what the value of biosimilar competition really is and how then to preserve it.

Biosimilar Bytes

FDA Releases Guidance on Biosimilar and Reference Product Promotion and Advertising

Earlier this month, the FDA released its guidance on advertising and promotion of biosimilars and reference products, with questions and answers for industry. The guidance provides suggestions (not rules) by the FDA for the characterization of biosimilars and interchangeable products in promotional materials, including the description of clinical study results, direct comparisons of reference products and their biosimilars. Several examples are provided within the guidance that marketers may find useful.

Valorum to Market Lupin’s Pegfilgrastim Biosimilar in the US

We recently reported on the FDA approval of Lupin’s first biosimilar, Armlupeg, and the company has now secured a US marketing partner to assist in commercializing the pegfilgrastim biosimilar.

On December 9, Valorum Biologics, based in New York, was named US marketing partner for Armlupeg. Lupin will be responsible for maintaining the supply chain for the pegfilgrastim biosimilar.

In June 2025, Valorum struck a marketing deal with Formycon AG for Ahzantive, Formycon’s aflibercept biosimilar.

In Other Formycon Partnership News

On December 9, Zydus Lifesciences Global FZE, signed an agreement with Formycon to market the German company’s pembrolizumab biosimilar in the US and Canada once it obtains regulatory approval. Formycon’s product, FYB206, has avoided the need for a phase 3 trial, but the timeline for 351(k) submission to the FDA has not been elucidated.

This agreement will mark the first foray into the North American biosimilar market for the Ahmedabad, India–based Zydus.