Why European prices now matter in the US
Since the May 2025 executive order on most-favored-nation pricing, US policy has moved from a target to concrete payment models. HHS defined the MFN target as the lowest price in an OECD country with GDP per capita of at least 60% of the US level. CMS has since set out three models: GENEROUS for Medicaid, GLOBE for Medicare Part B, and GUARD, proposed for Part D.
The consequence for manufacturers is simple. A list or net price agreed in London, Dublin or Berlin can now set a benchmark for the US. Launch pricing, sequencing and confidential discount structures in Europe have become part of US revenue planning.
Read our insight: What US most-favored-nation pricing means for European launches.
What we deliver
- MFN exposure analysis: which reference countries could set the benchmark for your product, and at what level
- Scenario modelling of GLOBE, GUARD and GENEROUS rules, including GDP (PPP) adjustment
- International reference pricing maps for Europe, Canada and other markets
- Launch price corridors and launch sequencing across the UK, Ireland and the EU
- Assessment of confidential discount and managed access options in UK and Irish HTA
- Price and value evidence that holds up in HTA and negotiation
- Briefings for leadership, boards and investors
Where HTA and pricing meet
In the UK and Ireland, the price that makes a medicine cost-effective at NICE or NCPE is often reached through a confidential discount. Under MFN, how and where that discount sits matters more than before. We connect the HTA evidence, the cost-effectiveness threshold analysis and the international pricing picture, so the decision is made once, with all of it in view. See UK HTA submissions and NCPE submissions.
A note on scope
We provide pricing, policy and health economic analysis. We do not give legal advice; contract and compliance questions should go to your legal advisers, and we are happy to work alongside them.