{{Subject}}
Real Chemistry’s weekly analysis of biopharmaceutical pricing and value news, provided free of charge.
Real Chemistry
Value Report
February 27, 2026
The Open Questions Behind FDA’s “Plausible Mechanism” Pathway

For families facing ultra-rare genetic conditions, traditional drug development timelines often offer little hope. In response, the FDA has proposed a “plausible mechanism” pathway that would allow highly individualized therapies – including gene-editing approaches – to be evaluated based on strong biological rationale and targeted evidence even when large trials are not feasible

Commissioner Marty Makary penned an op-ed in The Wall Street Journal detailing the FDA’s changes, while HHS Secretary Robert F. Kennedy Jr. said the move is intended to “cut unnecessary red tape, align regulation with modern biology, and clear a path for breakthrough treatments.”

But the announcement raises more questions than answers:

  1. Which therapies would qualify? Would the pathway be limited to gene therapies and treatments for ultra-rare conditions? Washington University’s Rachel Sachs cautioned that the “plausible mechanism” could be expanded into more ‘common’ disease areas where traditional trials are feasible, and that it wouldn’t be necessary to go through this pathway.”
  2. What operational details are still missing? Key elements related to manufacturing and toxicology remain undefined, which former FDA official Janet Woodcock noted could materially affect development costs and feasibility.
  3. How high will the evidentiary bar be? Despite FDA’s promise of flexibility, stakeholders question whether it will hold. “Several recent complete response letters indicate a hesitation to apply regulatory flexibility,” Annie Kennedy, chief mission officer of the EveryLife Foundation for Rare Diseases, testified at a Senate hearing yesterday.
  4. Is the broader ecosystem equipped to make this pathway work? Clinical trials for ultra-rare conditions remain difficult to conduct. “Add regulatory uncertainty, high per-patient development costs, and uneven access to diagnostic testing and expert clinical care – it is easy to see why promising science stalls,” said Rebecca Ahrens-Nicklas of Children’s Hospital of Philadelphia.
  5. Will this restore industry confidence? Recent FDA reversals have strained trust. A spokesperson for the Alliance for Regenerative Medicine said the framework “cannot distract from recent FDA regulatory surprises” affecting rare disease programs.

Leah Nebbia, Senior Group Director

Industry Comments Reveal the Likely Pain Points of MFN

Most favored nation drug pricing has moved from slogan to stress test. The reactions and submitted comments to two CMS models – GLOBE (covering Medicare Part B) and GUARD (Part D) – reveal just how quickly the international-based pricing policy is colliding with legal, operational and business realities.

  • Trade groups for biopharma are sharpening knives, not pencils. PhRMA and BIO argue the GLOBE and GUARD demos aren’t real “tests” at all, but preloaded mechanisms to extract rebates – sometimes in ways they say appear punitive, constitutionally suspect and beyond the regulator’s authority. Drugmakers also warn the approach imports foreign-style valuation frameworks that can narrow access, which would openly lay the groundwork for court fights if the demos are finalized.
  • Hospitals see a cost boomerang coming. The American Hospital Association backs the goal of lower prices but warns the models could raise hospitals’ drug acquisition costs if manufacturers reshape pricing and discount channels to reduce rebate exposure. AHA also flags points of operational chaos: identifying who’s “in” the randomized cohort in real time, handling coinsurance when supplemental coverage blunts out-of-pocket changes, and the lack of a clear appeals pathway when CMS miscalculates.
  • Small- and mid-size biotechs say licensing could become collateral damage. Companies that out-license ex‑U.S. rights argue they often don’t control foreign pricing –or even have visibility into it – yet could still be held liable under international benchmarks. They warn such demos could turn partnering into a “poison pill,” chilling the licensing deals that fund R&D and help smaller innovators survive.

Across the health care industry, the message is consistent: These Medicare demos may be marketed as affordability tools, but stakeholders fear both could function as a high-stakes test of supply chains, contracting structures and the legal limits of innovation itself.

Regan Thompson, Senior Manager

Trump Uses Major Speech to Push Congress on Drug Pricing

President Donald Trump addressed Congress in an annual State of the Union speech that sought to reclaim the political narrative on economic gains and affordability initiatives, including drug pricing.

In remarks lasting a record 107 minutes, Trump spent about three minutes touting how his administration has reduced “wildly inflated” U.S. drug prices. Trump cited his MFN approach as the reason that drug prices are now “the lowest anywhere in the world,” with discounts of “600% and more.”

While he did not debut new health-related policies, the president reiterated calls for Congress to pass legislation mandating MFN drug pricing in the U.S., acknowledging some hesitation among Senators but urging them to “codify it anyway.” PhRMA President and CEO Stephen Ubl released a statement saying that such a policy “would undermine U.S. competitiveness” rather than build on the “historic” PBM reforms signed into law weeks ago.

Guests in attendance on Tuesday night included the first customer of the recently launched TrumpRx who – as called out by the president – purchased discounted fertility medication through the site. Several Democratic members of Congress also invited constituents who they say now face “skyrocketing” insurance premiums as a result of federal inaction.

Andrew Wishon, Senior Manager

Circled on Our Calendar
  • March 2-3 – a ‘BIG’ Investment & Growth Summit, BIO
Quotes of the Week
  • “Policies have declared and undeclared purposes. We analyze the pros and cons of policies like Trump Rx or MFN…The political strategy behind them is usually undeclared but almost everything in health policy between now and November will be substantially about the midterms.” – Drew Altman, KFF
  • “The president needs an FDA that abides by its commitments and implements his vision for the future of medicine. We can help thousands of rare disease patients right now – and millions more in the future – with an FDA that follows his call.” – Tim Hunt, New York Post
  • “Today, pharmacy benefit managers and other middlemen often profit when prices stay high. Negotiated discounts can disappear before they ever reach the patient. That’s not reform, that’s a shell game.” – Sen. Ruben Gallego, D-Ariz., The Hill
Other News
See you next week …
–  Real Chemistry
Know a friend or colleague that would enjoy the Value Report?
Invite them to sign up here.
© Real Chemistry, All Rights Reserved.