How has drug pricing in Medicaid changed over time, and how will the model address the overall drug pricing landscape in Medicaid?
States collect rebates from drug manufacturers under the MDRP, and many states also negotiate additional supplemental rebates with drug manufacturers. These rebates help lower the net cost of drugs for Medicaid programs. However, Medicaid drug spending also continues to rise, with net spending on prescription drugs topping $60 billion in 2024, a $10 billion increase from 2022. This model will help further reduce the cost of drugs for state Medicaid programs by allowing them to access even lower international drug prices.
How will drug manufacturers benefit from participating in the model?
Participating manufacturers would offer lower prices to state Medicaid programs, which would make these drugs more affordable to states. In addition, manufacturers and CMS would negotiate suggested coverage criteria for the covered outpatient drugs. The development of these criteria would reduce a manufacturer’s burden of negotiating criteria in every state and could lead to greater access to their medications. Additionally, the manufacturer would not be required to negotiate additional supplemental rebates for covered outpatient drugs with prices similar to what other countries pay.
How does the model connect to the Administration’s recently announced agreements with drug manufacturers?
The Trump Administration has announced agreements with major pharmaceutical companies — including AstraZeneca, Pfizer, and EMD Serono — to bring American drug prices in line with the lowest paid by other developed nations. As a result of these agreements, these manufacturers will participate in the GENEROUS Model after certain terms are finalized, and state Medicaid programs will pay lower prices on drugs made by those manufacturers. The manufacturers that have entered into these agreements, plus any additional manufacturers that choose to participate in GENEROUS, would complete an RFA document and then negotiate the coverage terms for their drugs with CMS. The manufacturer would then sign a supplemental rebate agreement with each state that is interested in participating, as well as a participation agreement with CMS.
How will pricing and supplemental rebates be calculated?
Manufacturers would report to CMS the international net unit price for the covered outpatient drug and supplemental rebates would be invoiced to manufacturers by states on a quarterly basis, consistent with the calculation of the statutory Medicaid rebates.
The state would bill the manufacturer for supplemental rebates for the total units of the covered outpatient drugs paid for in that quarter for the covered outpatient drug, and the supplemental rebate amount would reflect the international pricing for the covered outpatient drug.
What flexibility do states have? Will agreements apply to all drugs?
GENEROUS is voluntary for state Medicaid agencies. In addition, states can determine for which (if any) covered outpatient drugs they would like to obtain a price similar to what other countries pay with respect to a participating manufacturer, providing additional flexibility for states to make the choices that align with their fiscal and coverage priorities. States may factor in their decision whether the drug price is cheaper after other manufacturer rebates, how it compares with prices of other drugs that they cover, and the length of the agreement they have with manufacturers for supplemental rebates on another drug.
How does GENEROUS affect the Medicaid Best Price and the 340B program?
The supplemental rebates provided to states by manufacturers under GENEROUS does not change Medicaid Best Price and therefore does not affect ceiling prices offered under the 340B Drug Discount Program. Under the MDRP, states obtain statutory rebates from manufacturers for branded covered outpatient drugs that are estimated using the calculated Medicaid Best Price, which is effectively the lowest price at which the manufacturer sells its drug in the United States to certain purchasers. Supplemental rebates do not affect the calculation of Medicaid Best Price.
What medications will be covered?
Included in the model will be the single source and innovator multiple sources covered outpatient drugs of voluntarily participating manufacturers.
What states are eligible to participate in the model?
All states and U.S. territories that participate in the MDRP are eligible to apply to participate in the model. CMS will review the state’s RFA to ensure that they have all the necessary authorizations to participate in the model.
Does this model qualify as an Advanced or MIPS Alternative Payment Model (APM)?
No, health care providers are not participants in the model and thus it does not qualify as an Advanced or MIPS APM under the Quality Payment Program.