How IRA, MFN, and HTA are rewriting oncology launch strategy
Amid a perfect storm of the US Inflation Reduction Act (IRA), Most Favoured Nation (MFN) pricing, and evolving health technology assessment (HTA) requirements, the questions of when, where, and even whether new cancer medicines are launched in the global market can have serious implications for drug developers further down the line.
In this Q&A, Paolo Correale, SVP of global access and pricing at EVERSANA, and Alan Crowther, general manager, global pricing, access, and digital solutions at EVERSANA, discuss how oncology companies are adapting their launch strategies to navigate a landscape where timing may be just as important as the science itself.
How much does launch order actually affect HTA outcomes and payer coverage decisions in oncology?
Paolo Correale (PC): Substantially. From established International Reference Pricing (IRP) dynamics to the more recent MFN framework, sequencing launch markets appropriately has a material impact on pricing and consequently, on net revenues.
HTA outcomes, specifically, are also directly impacted. In an increasingly competitive oncology market, retaining the ability to complete the HTA process ahead of a competitor (or before the Standard of Care loses exclusivity) translates into materially lower evidentiary pressure and, typically, more favourable HTA outcomes.
How fundamentally has the IRA, and the prospect of MFN-style pricing, changed how companies should think about the order in which they bring oncology indications to market?
Alan Crowther (AC): The risk of MFN is not uniform; it segments both products and companies based on exposure. Why is exposure segmented? Medicare, governed under MFN by GLOBE and GUARD, typically has the highest percentage of oncology patients as a channel in the US. Medicaid exposure, for comparison, can be very low to medium percentage of patients typically and is governed under MFN by the GENEROUS programme. Not every oncology product follows these demographic patterns, and not every company is exposed to both GUARD/GLOBE and GENEROUS – often, they are exposed in the near-term to only one.
Smaller companies that are typically exposed to GLOBE/GUARD may want to see if the indications have very different Medicare and Medicaid exposure and will want to consider prioritising those with very low exposure.
But if a product has only indications with low GLOBE/GUARD exposure, like desmoid tumours or seminoma, which have a patient age demographic typically of 20 to 50 years old, then that product is likely not heavily impacted by MFN and it can be ignored in the sequencing evaluation.
Finally, companies that have entered GENEROUS, typically larger companies, and have a GLOBE/GUARD exemption as a result, may choose not to consider MFN heavily in their sequencing.
How is MFN changing the way oncology companies think about the order in which they launch across countries?
PC: MFN is not merely reshaping launch sequencing decisions: it has prompted companies to reconsider whether to launch in certain markets at all. The central consideration is the ability to contain MFN exposure on the US business – still the dominant value driver for most oncology assets.
Launch order itself is also directly impacted: high-complexity MFN markets such as Germany and Japan, as well as lower-volume MFN markets like Ireland and Norway, are increasingly being considered for delayed launch or de-prioritisation; non-MFN reference basket markets are attracting greater interest as earlier launch candidates.
How are oncology companies deciding launch sequence when pricing pressure may shape the value of the entire asset?
PC: Optimal launch sequencing in oncology demands a combination of robust competitive intelligence and rigorous quantitative modelling.
Competitive intelligence is essential for tracking the evolution of treatment algorithms and standards of care. Pipeline surveillance alone is insufficient: intelligence must incorporate market-specific dynamics around reimbursement frameworks, prescribing restrictions, and realised net prices.
Quantitative modelling serves as the ultimate decision-making instrument, enabling scenario comparison across the full asset lifecycle value spectrum. Dedicated modelling layers are required to capture MFN risk exposure, in addition to the IRP dynamics already embedded in standard frameworks.
What is the biggest mistake companies make when sequencing tumour-type or line-of-therapy launches in the US?
AC: The two most common mistakes I see are:
1. Companies do not model the IRA impact properly – both for their own product and also competitors.
2. Companies under-estimate the impact of contracting, an emerging threat in oncology, on their pricing, and think that oncology is only about efficacy and OS. Payers are increasingly bringing aggressive contracting in oncology. Look to the behaviour of BTK inhibitors.
How much does the US pricing environment constrain the order in which oncology indications can be brought to market?
AC: The US pricing environment provides heavy consideration for sequencing. The impact here is less from MFN and more from IRA. The trajectory of revenue and whether the indications are orphan designations impacts heavily here.
- If only orphan oncology indications are launched, then the product is exempt, and so a product with many orphan oncology indications may choose to prioritise only those over non-orphan if the revenue calculation comes out positively for such a path vs the loss from being selected under IRA.
- The cumulative revenue of indications will drive the product into IRA, so a company will want to carefully consider at what point an indication launch will accelerate entry into IRA and whether that entry, and any subsequent indications, will offset the loss from IRA selection.
There are many more considerations here, including small vs large molecule, the company’s size, and other factors, so the calculation is actually quite complex.
How are commercial teams adjusting their evidence plans when later indications may change how the first launch is valued?
PC: Due to the highly competitive nature of oncology, there is a growing tendency to prioritise less competitive – 'blue ocean' – indications, as these are more likely to capture the attention of both HCPs and payers.
Beyond the benefit of lighter evidentiary requirements in less competitive indications, pursuing a highly competitive indication carries the additional risk of the standard of care shifting mid-trial, effectively triggering payer demands for more comparative evidence (head-to-head data, indirect treatment comparisons).
Is the bigger risk now launching too early, too late, or in the wrong order?
PC: Too late. Despite strategic challenges and potential missteps, inaction in the face of these challenges erodes asset lifecycle value while narrowing the therapeutic options available to patients and HCPs.
Early strategic planning, cross-functional alignment, and rigorous modelling can optimise sequencing and ensure that the evidence package available at launch is robust enough to withstand HTA scrutiny.
If you were designing the launch strategy for a first-in-class oncology asset today, what would you do differently from the playbooks companies were using five years ago?
PC: MFN is the most immediate answer; JCA follows closely, now mandatory for oncology assets, it carries particular strategic weight for first-in-class products, where cross-market clinical evidence alignment is hardest to achieve.
A number of governments have grown more receptive to early access for innovative therapies, prompting companies to move these markets higher in the global launch sequence. The Middle East is a clear illustration of this trend.
AC: In addition to MFN and JCA, IRA is a major factor in assessing a multi-indication launch, along with the orphan status of indications, how closely competitors are coming in launch, and whether there is potential for the asset in combinations like ADCs to extend the lifecycle value.
I would assess all of these in the calculations above and beyond the playbook from 5 years ago, pre-IRA and pre-MFN.
About the interviewees
Alan Crowther
Alan Crowther is a general manager of global pricing, access and digital solutions, specialising in consulting (strategy management and regulatory), data and software (pricing, HEOR), and pricing, reimbursement and market access.
Paolo Correale
Paolo Correale is a senior vice president for EVERSANA’s global pricing & access consulting team, where he specialises in commercialisation, market access, pricing, reimbursement & market access.
About the author
Eloise McLennan is the editor for pharmaphorum’s Deep Dive magazine. She has been a journalist and editor in the healthcare field for more than five years and has worked at several leading publications in the UK.
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