Margaux Hall Previews the 2026 Drug Pricing Outlook in Trending Video

Margaux Hall: Drug pricing continues to dominate the headlines in 2026. This is a topic that has swept attention for years now and will continue to do so in the year ahead. I am Margaux Hall, a partner in the Ropes & Gray health care group, based in Washington, D.C., and I lead the firm’s drug pricing and price reporting group. We advise biopharmaceutical manufacturers, other supply chain entities, and investors on the pharmaceutical supply chain, drug pricing, market access, and related business opportunities and calibration of legal risks. Here are three key areas to watch.

First, this year, I expect drug pricing to continue to be at the forefront of policy and market developments, with most-favored-nation and direct-to-consumer being prominent areas of activity. In 2025, we saw various executive actions and initiatives around most-favored-nation pricing, including a new proposed rule that is open for comment. In the U.S., we are accelerating towards most-favored-nation pricing models. At the same time, the Trump administration has shown a keen interest in direct-to-consumer models for commercializing drugs. This is an area of rapid growth. Over the next few months, TrumpRx and other direct-to-consumer platforms are expected to launch, offering new market access channels and pricing approaches. These platforms could help streamline the pharmaceutical supply chain and minimize the role for intermediaries within that channel.

This leads to the second area to watch—PBM (Pharmacy Benefit Manager) reform. For years now, there has been bipartisan discussion of PBM reform and the need to evolve the PBM business model. Recently, the Department of Labor proposed a rule that would implement additional transparency requirements for PBM remuneration in connection with ERISA plans. I also anticipate more intensive policy discussion of PBM reforms like spread‑pricing bans, rebate pass‑through, restrictions on preferred networks, and delinking PBM compensation from drug list prices. It remains to be seen which of these reforms might make it across the finish line in D.C.

And third, the Inflation Reduction Act (IRA) drug pricing reforms are now in full swing. At this stage, the IRA is seemingly here to stay. IRA implementation continues with ongoing Medicare price negotiations, with a potentially evolving tenor under the Trump administration. At the same time, the overhaul of the Part D program has taken place. This has brought some welcome relief for patients with high drug spend, especially now that there is a new $2,000 out-of-pocket cap on annual drug expenses under Part D. This is some perhaps rare, good news in this space, and provides really important tailwinds for access. At the same time, the new manufacturer discount program and allocation of financial liability places additional financial burdens on biopharmaceutical manufacturers, particularly once patients exceed that $2,000 out-of-pocket limit. 

The on-the-ground market dynamics continue to evolve in response to these legal changes. On top of keeping pace with the many legal developments in the drug pricing arena, we are actively advising clients on those market access dynamics and related opportunities.

Bottom line: drug pricing will remain a hot topic to watch in 2026. I expect further legal, policy, and political developments in this space.