The most-favored-nation (MFN) interim final rule issued in late November is not the first time the current administration has attempted to implement some kind of drug pricing model based on prices in other countries.
The first effort, the International Pricing Index (IPI) model (83 Fed. Reg. 54546, Oct. 30, 2018), was unveiled on Oct. 25, 2018, in an Advanced Notice of Proposed Rulemaking (ANPRM). It proposed that instead of CMS reimbursing Medicare Part B drugs at their average sales price (ASP) plus 6%, it would reimburse these medications per an IPI based on drug pricing data from not only the U.S. but also 16 other developed countries (RSP 11/18, p. 1).