We Work For Health Response to Commonsense Policy Options to Lower Drug Prices for Patients Request for Information

July 30, 2026

The Honorable Ron Wyden

Ranking Member

Committee on Finance

United States Senate

219 Dirksen Senate Office Building

Washington, D.C. 20510

Re: We Work For Health Response to Commonsense Policy Options to Lower Drug Prices for Patients Request for Information

Dear Senator Wyden:

We Work For Health (WWFH) appreciates the opportunity to respond to Ranking Member Wyden’s Request for Information, “Commonsense Policy Options to Lower Drug Prices for Patients.” We share your concerns about lowering drug costs for patients while preserving incentives for innovation in America, and commend the search for commonsense solutions to address these challenges. It is with these important considerations in mind that we share our feedback.

We Work For Health brings together national and local business leaders, labor organizations, biopharmaceutical companies, patient advocacy groups and other healthcare stakeholders united in support of policies that foster medical innovation and improve patient access to lifesaving and life-enhancing treatments. For decades, the United States has led the world in biomedical innovation, driven by a strong ecosystem that supports scientific research, medical advancement and the development of breakthrough therapies, diagnostics and technologies. This leadership not only improves and saves lives but also drives economic growth, sustains millions of high-quality jobs and strengthens America’s global competitiveness.

As the Committee considers proposals to lower healthcare costs for patients, WWFH appreciates its commitment to improving affordability and access. However, we are concerned that policies relying on government-imposed price controls risk undermining the very innovation ecosystem that produces the next generation of medical breakthroughs. While intended to address patient costs, such policies fail to directly confront the market dynamics that contribute to out-of-pocket expenses and instead threaten future investment in research and development.

We therefore urge the Committee to prioritize reforms that increase transparency and accountability throughout the pharmaceutical supply chain, particularly the pharmacy benefit manager (PBM) reforms outlined in the proposal, which can help lower patient costs without jeopardizing innovation, jobs or future treatments. At the same time, Congress should reject government price-setting policies, including the Inflation Reduction Act’s Medicare drug price controls and Most Favored Nation (MFN)-style pricing provisions, which risk undermining investment in research and development, reducing incentives for innovation and limiting patients’ access to future breakthrough therapies.

Lowering Drug Prices

WWFH rejects the notion that government-imposed price controls are an effective approach to strengthening the U.S. healthcare system or sustaining the nation’s leadership in biopharmaceutical innovation, and we urge the Committee to reconsider these recommendations.

While the Committee raises concerns about MFN pricing policies, the proposal would advance similar concepts by expanding and accelerating Medicare drug price negotiations and incorporating international reference pricing into the process.

However, these policies rely on pricing benchmarks derived from healthcare systems – typically drawn from 19 health systems – that operate under fundamentally different policy frameworks and priorities than those in the U.S. In many of these countries, government price controls are coupled with restrictive coverage and reimbursement decisions that can delay patient access to new medicines and limit treatment options. Many also rely on quality-adjusted life years (QALYs) to inform coverage and reimbursement decisions, a practice that Congress expressly prohibited under the Affordable Care Act because of concerns that it could discriminate against older adults and people with disabilities. Adopting similar mechanisms in the U.S. risks importing those tradeoffs, potentially reducing access to innovative therapies and weakening incentives for future research and development. One estimate suggests expanded price controls could result in more than 200 fewer new medicines over the next decade and 1.1 million lost American jobs.

Furthermore, while these proposals are often presented as measures to reduce healthcare costs, they do little to address the factors that most directly affect what patients pay at the pharmacy counter. The Committee’s recommendations focus primarily on reducing spending by government payers, which does not necessarily translate into meaningful savings for patients at the pharmacy counter. Rather than expanding price controls, Congress should pursue targeted reforms that directly confront the intermediaries and incentives within the prescription drug supply chain that contribute to higher patient costs. Countries cited for reference pricing do not have PBMs, 340B hospitals and other market middlemen that absorb half of all US drug spending. Markups of 340B entities can exceed drug prices in some countries by as much as 700% and PBM rebates often are multiples higher than what a drug costs in many countries. Addressing drug spending requires a broader approach that includes the upward pricing pressures created and perpetuated by middlemen in the system.

The Committee also recommends increasing the number of drugs subject to Medicare price negotiation and making them eligible earlier in their lifecycle. This recommendation directly conflicts with the Committee’s concerns with negatively impacting innovation and ignores the significant innovation that occurs after a medication’s first FDA approval.

Lowering Patient Out-of-Pocket Costs

The Committee is right to highlight the role that pharmacy benefit managers (PBMs) play in shaping prescription drug costs and patient access. Today, PBMs exert significant influence over formulary design, cost-sharing structures and coverage decisions, affecting both what patients pay at the pharmacy counter and which medicines are available to them. WWFH believes greater transparency and accountability throughout the prescription drug supply chain is warranted. Concerns about rebate structures, fee arrangements and other market dynamics deserve careful scrutiny to ensure that savings are reaching patients, and that incentives are aligned with improving patient access and affordability.

Sustaining American Biopharmaceutical Innovation

The RFI appropriately recognizes the importance of strengthening the United States’ biomedical innovation ecosystem and identifies opportunities to expand basic research, translational research and clinical development in areas of unmet medical need. These efforts are particularly important as global competition intensifies, including from China, whose biopharmaceutical sector has experienced significant growth in recent years.

We support the Committee’s efforts in enhancing domestic clinical trial capacity, improving development efficiency and maintaining America’s leadership in biomedical innovation to compete with China. The proposal includes several constructive ideas, including increased investment in basic and translational research, efforts to bridge the "valley of death" between scientific discovery and commercial development, and targeted support for drug development accelerators, small biotech companies and high-risk therapeutic areas.

At the same time, it is important to recognize that public and private investment are complementary and mutually reinforcing components of the innovation ecosystem. While public funding plays an essential role in supporting early-stage scientific discovery, the development of new medicines ultimately depends on sustained private-sector investment to advance promising research through clinical trials and regulatory approval. Policies that reduce the expected return on successful therapies can weaken the incentives that drive this investment. Venture capital firms, biotechnology companies and pharmaceutical manufacturers make long-term investment decisions based on the anticipated value of future innovations. If government policies substantially reduce that value, private investment may shift away from the very high-risk research areas policymakers seek to encourage. As a result, increased public investment alone may not be sufficient to offset the diminished incentives for private capital to support the later stages of drug development.

The Committee also suggests drawing lessons from the Inflation Reduction Act (IRA) when designing future biopharmaceutical innovation incentives. While WWFH supports efforts to improve affordability and patient access, we believe it is important to assess the IRA’s full impact before using it as a model for future policy.

By accelerating the time under which certain medicines become subject to government-set pricing, the policy reduces the period during which manufacturers can earn market-based returns on successful therapies. An economic analysis from the University of Chicago estimated that this change could reduce revenue by as much as 8% and research and development spending by approximately 12.3%. The study further projected that these reductions could result in 79 fewer small molecule medicines, 188 fewer approved indications and the loss of approximately 116 million life-years lost over the next 20 years. While stakeholders may debate the precise magnitude of these effects, such findings underscore the importance of carefully considering the innovation tradeoffs associated with expanding government price controls.

For these reasons, WWFH encourages the Committee to continue polices that strengthen America’s innovation ecosystem, while avoiding measures that could unintentionally undermine the private-sector investment necessary to translate scientific discoveries into new treatments and cures. We support efforts to improve patient affordability, expand access and promote competition throughout the healthcare system, but believe these goals can be achieved without resorting to policies that risk weakening the foundation of U.S. biopharmaceutical innovation. Rather than expanding government price controls, policymakers should prioritize reforms that directly address patient costs, strengthen the efficiency of the healthcare system and preserve the incentives that have made the United States the global leader in medical innovation.

Thank you for the opportunity to comment on this important matter.

Sincerely,

Dan Leonard

Executive Director

We Work For Health

www.weworkforhealth.org