普通外文研报
CMS Gets Under The Skin Of Subcutaneous Drugmakers
研报英文原文证据摘录
CMS Gets Under The Skin Of Subcutaneous Drugmakers
Pharmaceuticals (Major) & Large Cap Biotechnology
Pharmaceuticals - Major - Market Weight
CMS Gets Under The Skin Of Subcutaneous Drugmakers June 15, 2026
The Wolfe Byte
CMS' proposed rule to negotiate subcutaneous formulations together with their single source drug has confirmed
a concern that frankly many investors had already seen coming. MRK & BMY see this as little surprise, while JNJ
reiterates 2034 for Darzalex given orphan exclusion.
The Centers for Medicare Services (CMS) proposed that subcutaneous formulations of a drug will be considered part
of the same qualifying single source drug. CMS proposed a rule last Friday that looks to establish new guidance for the
Medicare Drug Price Negotiation Program (MDPNP) for initial price applicability year 2029 and beyond. Recall that under
the current policy established for years 2026-2028, a distinct combination comprised of two or more active moieties
(active ingredients/antigen components) was considered its own active moiety. CMS recognized that drug manufacturers
were utilizing a "fixed combination drug loophole" whereby manufacturers would avoid negotiation selection of a drug
by approving and marketing a new formulation through the addition of another active ingredient, enabling an alternative
route of administration. Of course, we are familiar with this process via the new subcutaneous formulations that IV
drugs launch with for improved convenience and as part of drug life cycle management. With this proposed rule, CMS
seeks to consider any fixed combination drug with active ingredients that were added for the purpose of creating a new
formulation/altering the route of administration as the same NDA/BLA as its original reference drug. Specifically, CMS
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