Legislation & Regulation

AMCP’s Policy Outlook 2026 provides a forward-looking analysis of the political, legislative, and regulatory developments poised to shape managed care pharmacy in the year ahead, from the 2026 midterm elections and government funding deadlines to major policy debates around PBM reform, Medicare drug price negotiation, GLP-1 coverage, direct-to-consumer drug models, and the 340B program. Designed to help managed care professionals anticipate change and plan strategically, the report breaks down what to expect from Congress, federal agencies, and the administration—and what it all means for patient access, costs, and pharmacy operations. Download the full Policy Outlook 2026 to explore the key issues, timelines, and implications that will define the policy environment in the coming year.

On Dec. 19, the Trump administration closed out a year of international pharmaceutical reference pricing announcements with the publication of CMS’s proposed Global Benchmark for Efficient Drug Pricing (GLOBE) and Guarding U.S. Medicare Against Rising Drug Costs (GUARD) models, as well as the release of nine additional Most-Favored-Nation (MFN) pricing arrangements with major pharmaceutical manufacturers. The announcements align with the Trump administration’s goal of lowering the prices that American patients pay for prescription drugs to the prices paid in similarly developed countries, as well as May 12 Executive Order on delivering MFN prices to patients.

On Dec. 4, Senators Mike Crapo (R-ID) and Ron Wyden (D-OR), Chair and Ranking Member of the Senate Committee on Finance, introduced the PBM Price Transparency and Accountability Act (S. 3345). The bill’s introduction signifies Congress’ appetite towards passing pharmacy benefit manager (PBM) reform, with many of the bill’s provisions included in earlier reform proposals adopted at the state level. This includes bans on the use of spread pricing arrangements, delinking PBM compensation from the price of a drug, and increased transparency into PBM contracts and business practices.

On Friday, November 21, the Centers for Medicare and Medicaid Services (CMS) released CY 2026 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) payments Final Rule, updating Medicare rates and announcing policy changes. The rule includes payment increases for hospitals and ASCs meeting quality reporting requirements and outlines significant reforms related to drug payment and procedural lists. There is a 30-day notice for comments on IRA negotiation factors for 2028 (comment period will begin once forms are published).

As mostly non-pediatric organizations representing public health, older adults, patients, family caregivers, consumers and healthcare workers, we support everyone having access to every vaccine they need, regardless of their age. In the United States alone, routine childhood vaccinations for children born between 1994 and 2023 are projected to prevent about 1.13 million deaths, and hundreds of millions of illnesses and hospitalizations. Put simply, childhood vaccines make healthy adults.