On September 30, 2025, the Centers for Medicare & Medicaid Services (CMS) issued final guidance (Final Guidance) for initial price applicability year (IPAY) 2028 of the Inflation Reduction Act (IRA) Drug Price Negotiation Program (DPNP). The Final Guidance also implements polices for effectuation of the Maximum Fair Price (MFP) for IPAYs 2026 through 2028….
By: Hogan Lovells
By: Hogan Lovells