Anne Hensley
Compliance Practice Leader
Background
On September 25, 2025, the Trump Administration announced plans via social media to impose a 100% tariff on brand-name prescription drugs unless manufacturers are actively building manufacturing facilities in the U.S. These tariffs were slated to begin as early as October 1.
On September 29, the Pharmaceutical Research and Manufacturers of America (PhRMA) announced it will launch AmericasMedicines.com in January 2026, a website connecting patients to medications through DTC programs.
On September 30, the Administration introduced “TrumpRx,” a direct-to-consumer (DTC) website offering drugs at government-negotiated prices. Pfizer is the first manufacturer participating, offering lower drug costs and investing $70 billion in U.S. manufacturing in exchange for a three-year tariff waiver. 10 days later Astra Zeneca announced an agreement with the Administration that would give State Medicaid programs access to Most Favored Nation Pricing.
What does this mean?
Tariffs target branded, patented drugs, which account for roughly 10% of drugs dispensed under pharmacy benefits; generic drugs are currently unaffected. While we are waiting for more details on how these proposals will be operationalized, TrumpRx has the potential to offer consumers significant savings through discounted cash pricing. Its pricing relative to commercial, Medicare, and Medicaid plans is not yet clear. PhRMA’s new website aims to provide value if manufacturers price drugs reflecting rebate values.
TrumpRx and PhRMA’s DTC programs are not replacements for existing insurance coverage but alternative purchasing options.
Initial indications suggest that that the discounted pricing through TrumpRx will be available to all Americans using a discounted cash pay price reflecting the value of the rebate. It is important to note that at least initially this solution does not contemplate what members covered under Commercial plans currently pay via copays or coinsurance that could result in a lower out of pocket cost for the member. Additionally, it does not provide member level tracking or credit for any cash pay prescription drugs towards the member individual deductibles or out of pocket maximum. While this may change over time, it is not currently a tool that employers can use within their existing health insurance plans to reduce costs. This is not a comprehensive or final shift in the pharmaceutical market but potentially the start of significant changes.
What could be next?
These announcements do not yet represent finalized policies; many details are still being developed and subject to change. The last few weeks reinforce the value of waiting and watching to see what is finalized.
Other manufacturers may follow Pfizer’s lead by lowering prices via TrumpRx and increasing U.S. manufacturing to avoid tariffs. Pharmacy Benefit Managers (PBMs) may have a limited or evolving role in processing claims and managing clinical edits for DTC programs.
What should employer plan sponsors do now?
It is not yet clear how these programs will integrate with existing insurance plans or impact overall drug pricing structures. The role of PBMs and employers in these new models is still uncertain and may vary widely.
Employers will likely look to explore new benefit strategies to support DTC drug purchases. Any such strategy or plan design should be analyzed in conjunction with applicable laws and/or regulations.
We will continue to monitor this topic and update this article as new announcements are shared. Get in touch with a health and welfare compliance consultant if you have questions.
