How far are IRA-negotiated prices below the CMS comparison list price?
The first 10 IRA-negotiated prices took effect January 2026, with reduction against the CMS comparison list price from $292 to $9,141 — Stelara (ustekinumab) leads at $4,695 vs $13,836 before negotiation. Roughly 8.6M Part D members take at least one negotiated drug.
Difference from the CMS comparison list price, by drug
- CMS negotiated price (maximum fair price, MFP)
- The price CMS negotiated under the IRA, effective January 1, 2026, on a standardized 30-day supply.
- CMS comparison list price
- The pre-negotiation reference price CMS published alongside each MFP, on the same standardized basis.
- Difference
- Comparison list price minus MFP. A MedicareInsights subtraction of two CMS-published prices. It is not net of rebates, not a plan’s realized liability change, and not what any beneficiary pays or saves at the counter.
Values are the CMS comparison list price minus the CY2026 negotiated price (MFP), in USD on the standardized 30-day-supply basis. This is a published price difference, not realized plan or beneficiary savings and not an amount received on a fill. Member counts are beneficiaries with ≥1 fill of the drug.
Data table — all 10 negotiated drugs
| Drug | Class | CMS comparison list price | Negotiated price (MFP) 2026 | Difference | Members (K) |
|---|---|---|---|---|---|
| Stelara (ustekinumab) | Inflammatory | $13,836 | $4,695 | −$9,141 | 94 |
| Imbruvica (ibrutinib) | Oncology | $14,934 | $9,319 | −$5,615 | 82 |
| Enbrel (etanercept) | RA/Inflammatory | $7,106 | $2,355 | −$4,751 | 180 |
| Januvia (sitagliptin) | Diabetes | $527 | $113 | −$414 | 1,640 |
| Farxiga (dapagliflozin) | Diabetes/HF | $556 | $178 | −$378 | 890 |
| Fiasp/NovoLog (insulin aspart) | Diabetes | $495 | $119 | −$376 | 770 |
| Jardiance (empagliflozin) | Diabetes/HF | $556 | $197 | −$359 | 1,120 |
| Entresto (sacubitril) | Heart Failure | $628 | $295 | −$333 | 560 |
| Eliquis (apixaban) | Anticoagulant | $529 | $231 | −$298 | 1,840 |
| Xarelto (rivaroxaban) | Anticoagulant | $489 | $197 | −$292 | 1,380 |
So what / Now what Interpretation
Negotiated prices cut plan liability on exactly the drugs that dominated catastrophic-phase spend, partially offsetting the OOP-cap cost shift. For pharma, the MFP resets net-price benchmarks for the whole class — including drugs not on the list.
- Payers: rebase 2027 bids on MFP acquisition costs; legacy rebate assumptions for these 10 molecules are obsolete.
- Pharma market access: model class-level spillover — payers will anchor formulary negotiations for competitors to the MFP.
- Watch the next negotiation cycle list (announced early 2027 for CY2028) — this page versions with each cycle.
Provenance — Part D benefit parameters, CY2022–CY2026
- Source file
- CMS Part D benefit parameter announcements; IRA statutory provisions
- Vintage
- CY2026 final parameters
- Last updated
- April 7, 2026
- Refresh cadence
- Annual (April announcement)
- Method
- Published standard deductible and IRA out-of-pocket cap by contract year; carrier deductible-waiver strategies compiled from public formulary filings.
- Known limitations
- Waiver-strategy rows are compiled from public filings and may lag mid-year formulary changes.