Market Access Intelligence

Market Access Intelligence — March 20, 2026
MARKET ACCESS INTELLIGENCE • Weekly Digest • March 20, 2026
The Drug Channels Leadership Forum convened in Miami this week, producing the first market-wide data on the post-reform pharmacy landscape: DCI estimates total U.S. prescription dispensing revenues reached $751 billion in 2025, up 10%, with GLP-1 drugs accounting for 60% of retail pharmacy revenue growth over five years. On Capitol Hill, bipartisan House members are circulating a letter to ban the 340B rebate model in must-pass federal appropriations legislation—a legislative vehicle that could settle the rebate-vs-discount architecture debate without standalone action. And PCMA filed a formal request urging DOL to rescind its proposed PBM transparency rule for self-insured plans, arguing it is duplicative of the CAA 2026 provisions—a defensive signal that the PBM industry views the commercial-market transparency mandate as the highest-impact reform now in play.

PHARMACY MARKET STRUCTURE

Pricing DCI: U.S. pharmacy dispensing revenues hit $751 billion in 2025 as GLP-1s reshape the market

Drug Channels Institute published its annual pharmacy rankings this week, ahead of the full 2026 Economic Report (releasing March 24). Total prescription dispensing revenues at retail, mail, long-term care, and specialty pharmacies reached an estimated $751 billion in 2025—a 10% increase over 2024's $683 billion. GLP-1 agonist drugs are now the dominant structural driver: over the past five years, GLP-1 dispensing revenue growth has accounted for approximately 60% of retail pharmacies' total revenue growth. The top 15 companies captured nearly three-quarters of all dispensing revenues. The four largest organizations—CVS Health, Walgreens, Cigna (Evernorth), and UnitedHealth Group (Optum)—together accounted for more than half of the total U.S. market, underscoring the degree to which vertical integration has consolidated pharmacy economics under PBM-insurer parent companies.

The $751 billion figure provides the baseline against which all market access strategy must be calibrated. The GLP-1 concentration is particularly significant: when a single therapeutic category drives 60% of revenue growth, every formulary decision, prior authorization policy, and copay design in the GLP-1 space has outsized impact on pharmacy P&Ls. This creates both opportunity and risk. For manufacturers launching GLP-1 competitors (oral semaglutide, tirzepatide extensions, next-generation candidates), the pharmacy channel economics favor them—pharmacies need GLP-1 volume. But for specialty and rare disease manufacturers, the GLP-1 revenue surge means pharmacy chains and PBMs are increasingly optimizing their entire benefit structure around high-volume, high-revenue products, potentially marginalizing lower-volume specialty therapies in formulary negotiations. The DCI report's vertical integration analysis (Exhibit 267) will be the definitive reference for mapping who controls what in the post-reform drug channel.

340B PROGRAM

340B House members push to ban 340B rebate model in must-pass appropriations bill

340B Report reported that a bipartisan group of House lawmakers is circulating a letter to include language in must-pass federal appropriations legislation that would explicitly ban the 340B rebate model. The effort builds on the 163-member bipartisan letter sent to HHS Secretary Kennedy in September 2025 urging the agency to abandon the rebate pilot. HHS formally withdrew the current pilot in February 2026 following court losses, but agreed to potentially restart the administrative process with new guardrails. Using an appropriations rider would go further than the administrative withdrawal—it would prohibit the executive branch from spending federal funds to implement any rebate model, effectively requiring congressional authorization for any future shift from upfront discounts to post-purchase rebates.

The appropriations strategy is clever because it avoids the committee process that has stalled standalone 340B reform legislation. Must-pass spending bills are the most reliable legislative vehicle in the current Congress, as the CAA 2026 PBM reforms demonstrated. If the rebate ban language attaches to an appropriations bill, manufacturers lose the ability to use the executive branch as a back door to restructure 340B economics without congressional authorization. Separately, a national 340B advocacy group launched a litigation fund this week specifically to help states defend contract pharmacy access laws against manufacturer lawsuits. This is a material development: it signals that the covered entity community is professionalizing its litigation capacity to match PhRMA's legal resources in the state-by-state contract pharmacy fights.

The 340B litigation landscape continues expanding. 340B Report's latest roundup tracks active litigation in Maryland, Rhode Island, South Dakota, and Oregon, adding to existing cases in Colorado, Hawaii, Vermont, and New Mexico. Endpoints News reported that Sanofi, AbbVie, Novartis, and AstraZeneca face a revived 340B pricing case—a court action that could reopen manufacturer liability for historical 340B pricing practices. The combination of legislative bans (appropriations rider), state-level protections (contract pharmacy laws), and revived litigation creates a multi-front environment where manufacturers must defend their 340B positions simultaneously in Congress, state legislatures, and federal courts.

PBM REFORM IMPLEMENTATION

Policy PCMA urges DOL to rescind commercial PBM transparency rule; pharma industry celebrates CAA 2026

PCMA filed a formal request (March 19) urging the Department of Labor to rescind its proposed PBM remuneration transparency rule for self-insured employer plans, arguing it is duplicative of the CAA 2026 provisions already enacted. The DOL proposed rule—comment period closing March 31—would require per-drug disclosure of manufacturer rebates, administrative fees, spread pricing, and pharmacy clawbacks. Ropes & Gray's analysis noted that the DOL rule targets the self-insured employer market segment, which is the largest in U.S. health insurance and the segment where CBO projects the greatest fiscal impact from PBM reform ($1.865 billion of the $2.12 billion total deficit reduction score).

PCMA's push to rescind the DOL rule reveals the PBM industry's strategic calculus. The CAA 2026 mandates transparency primarily in Medicare Part D; the DOL rule would extend similar requirements to commercial employer plans. If both apply simultaneously, PBMs face transparency mandates across their entire book of business—leaving no market segment where opaque remuneration structures can persist. PCMA's "duplicative" argument is a bet that framing the DOL rule as regulatory overreach, rather than fighting it on substance, provides the best chance of preserving some operational flexibility in the commercial market. Separately, PCMA published a March 16 blog post noting that PhRMA's CEO publicly celebrated the PBM reform legislation—a detail PCMA highlights as evidence that the CAA 2026 serves manufacturer interests. For market access teams, the practical takeaway is that commercial-market transparency is the highest-stakes implementation battleground for the next 12 months.

BIOSIMILAR PIPELINE

Biosimilar Sandoz and Samsung Bioepis expand partnership with up to five biosimilars, targeting Entyvio

FiercePharma reported (March 18) that Sandoz has entered a global licensing and commercialization agreement with Samsung Bioepis for up to five biosimilar candidates. The lead asset is SB36, a vedolizumab biosimilar referencing Takeda's Entyvio, currently in preclinical development. Samsung Bioepis will handle development, manufacturing, and regulatory filings; Sandoz will commercialize globally (excluding China, Hong Kong, Taiwan, Macau, and South Korea). The deal builds on the companies' existing partnership for PYZCHIVA (ustekinumab biosimilar, launched in the U.S. in February 2025) and EPYSQLI (eculizumab/Soliris biosimilar). The agreement could expand Sandoz's total biosimilar portfolio to 32 assets, which the company described as an industry-leading position targeting the estimated $320 billion biosimilar loss-of-exclusivity opportunity over the next decade.

The Entyvio biosimilar targeting is strategically significant for market access planning. Entyvio generated approximately $5 billion in worldwide sales in 2025, with U.S. sales accounting for roughly $3 billion. Takeda's regulatory protection extends into May 2026, but key patents run through 2032—meaning commercial launch timing remains uncertain and will depend on patent litigation outcomes. For market access teams at payers, the Entyvio biosimilar pipeline (Samsung Bioepis/Sandoz is not the only developer) signals that IBD formulary economics will shift materially by late decade. Samsung Bioepis separately announced plans to develop biosimilar versions of Dupixent, Tremfya, Enhertu, Ocrevus, and Taltz, targeting a 20-product portfolio by 2030. The broader implication: the next wave of biosimilar competition will extend beyond established categories (Humira, Stelara) into immunology, oncology, and neuroscience biologics that currently face no biosimilar pressure—fundamentally changing the long-term economics of specialty drug market access.

QUICK TAKES

  • Pricing Health Affairs study found that brand-name ICS-LABA inhaler list price reductions in 2024 were associated with increased generic uptake—evidence that proactive manufacturer price cuts ahead of IRA negotiation can accelerate rather than slow competitive entry. This finding has direct implications for the 15 drugs in IRA Cycle 2 (2027 price applicability): manufacturers weighing preemptive list-price reductions should model whether the strategy protects market share or inadvertently opens the door to generic competition.
  • 340B National 340B advocacy group launches litigation fund to help states defend contract pharmacy access laws against manufacturer lawsuits. Active litigation now spans Maryland, Rhode Island, South Dakota, Oregon, Colorado, Hawaii, Vermont, and New Mexico. The 5th Circuit's 2025 unanimous decision upholding Louisiana's law remains the strongest precedent for state protections, while DOJ's Colorado brief backing AbbVie represents the strongest federal intervention on the manufacturer side.
  • Policy PCMA: PhRMA celebrates PBM reform — In a pointed March 16 blog post, PCMA highlighted PhRMA CEO's public celebration of the CAA 2026 provisions as evidence that PBM reform serves manufacturer interests. PCMA argues that with PBMs "handcuffed," manufacturers face no counterbalance to list-price inflation. The political framing battle over who benefits from PBM reform will shape the next round of drug pricing legislation.
  • Biosimilar FDA publishes revised biosimilar development guidance (March 10) — The fourth revision of the BPCI Act Q&A guidance updates analytical assessment, clinical study requirements, and interchangeability standards. The revision signals FDA's evolving approach as the biosimilar pipeline accelerates beyond first-generation products into complex oncology and autoimmune biologics.
  • 340B Sanofi, AbbVie, Novartis, AstraZeneca face revived 340B pricing case — Endpoints News reported that four major manufacturers face a revived court action over historical 340B pricing practices. A ruling reopening manufacturer liability could create retroactive financial exposure and strengthen covered entities' leverage in the ongoing 340B reform negotiations.

WHAT TO WATCH NEXT

DCI 2026 Economic Report on U.S. Pharmacies and PBMs—March 24

Drug Channels Institute releases its 17th edition next week: 12 chapters, 500+ pages, 270 exhibits, nearly 1,300 endnotes. The report will contain the definitive vertical integration analysis (Exhibit 267), updated PBM market share data, specialty pharmacy revenue breakdowns, and the most current assessment of how the Net Pricing Drug Channel (NPDC) transition is reshaping economics across all participants. DCI's April 10 webinar will provide a forward-looking PBM industry update analyzing the transition challenges ahead of the August 2028 delink deadline. This report sets the analytical baseline for every market access strategy discussion through 2027.

DOL PBM transparency rule comment deadline—March 31, 2026

PCMA's March 19 rescission request will be one of many comments the DOL receives before the deadline. The rule would require per-drug disclosure of manufacturer rebates, administrative fees, spread pricing, and pharmacy clawbacks for self-insured employer plans—the largest market segment in U.S. health insurance. If finalized as proposed, disclosures would apply to plan years beginning on or after July 1, 2026. Market access teams at manufacturers and PBMs should be preparing for a scenario where both CAA 2026 (Part D) and DOL (commercial) transparency mandates are simultaneously in effect, creating full-book-of-business visibility into remuneration flows for the first time.

CVS Caremark Prolia/Forteo biosimilar formulary switch—April 1, 2026

CVS Caremark's formulary switch from branded Prolia and Forteo to biosimilar alternatives takes effect April 1 on major national commercial template formularies. Ospomyv (Cordavis/CVS private-label) and Stoboclo (Celltrion) replace Prolia; generic teriparatide, Bonsity, and Tymlos replace Forteo. This is the first major test of the private-label biosimilar model outside the Humira and Stelara categories. Watch for Amgen's response—the company faces franchise displacement in osteoporosis following the same pattern that hit AbbVie's Humira.

DATA SNAPSHOT

  • U.S. pharmacy dispensing revenues (2025): $751 billion, +10% YoY. GLP-1 drugs = 60% of retail pharmacy revenue growth over past 5 years. Top 4 companies (CVS, Walgreens, Cigna, UnitedHealth) = 50%+ of total market (Drug Channels Institute)
  • 340B rebate model: HHS formally withdrew pilot Feb 2026. House members now circulating appropriations rider to ban any future rebate model. 163 bipartisan members previously signed anti-pilot letter. New 340B litigation fund launched for state contract pharmacy defense (340B Report)
  • Sandoz biosimilar pipeline: Partnership with Samsung Bioepis for up to 5 new biosimilars, expanding portfolio to 32 assets. Lead: SB36 (vedolizumab/Entyvio biosimilar, preclinical). Entyvio 2025 WW sales: ~$5B. Samsung Bioepis targeting 20-product portfolio by 2030 (FiercePharma)
  • CAA 2026 PBM reform: $2.12B CBO deficit reduction; $1.865B from commercial oversight. 100% rebate pass-through by Aug 2028. $10K/day civil penalties for transparency noncompliance. DOL commercial rule comment deadline: March 31. PCMA filed rescission request March 19 (KFF)
  • Biosimilar formulary dynamics: CVS Caremark Prolia/Forteo biosimilar switch April 1 at >50% cost reduction. Humira: 14 biosimilars on market, ~22% volume share. Stelara: 12 biosimilars + 1 unbranded biologic, 5%–90% list-price discounts. Of ~73 approved U.S. biosimilars, 34% remain uncommercialized (Drug Channels)

MARKET ACCESS POSITIONING HEATMAP

Winners this week:

  • 340B covered entities / safety-net hospitals — Appropriations rider to ban rebate model, new litigation defense fund, and HHS withdrawal of pilot collectively strengthen the upfront discount architecture; manufacturers' ability to impose rebate models through executive action is narrowing
  • Sandoz — Samsung Bioepis deal expands portfolio to potential 32 assets targeting the $320B biosimilar loss-of-exclusivity opportunity; Entyvio biosimilar positions Sandoz in the next wave of high-value IBD market competition
  • Self-insured employers / plan sponsors — DOL proposed rule (if finalized) plus CAA 2026 would create full-book-of-business PBM transparency for the first time; PCMA's rescission request signals the industry views this as the highest-impact reform
  • CVS Caremark / Cordavis — April 1 Prolia/Forteo biosimilar formulary switch extends the private-label playbook beyond Humira/Stelara into osteoporosis with >50% cost reduction

Under pressure this week:

  • Amgen (Prolia/Forteo) — CVS Caremark formulary exclusion effective April 1 replicates the Humira displacement pattern; osteoporosis franchise faces accelerating biosimilar competition across all three Big Three PBM formularies
  • Takeda (Entyvio) — Sandoz/Samsung Bioepis deal signals that vedolizumab biosimilar competition is being industrialized; patent protection runs through 2032 but preclinical development timelines suggest mid-decade competitive pressure
  • PBM industry (PCMA) — DOL rescission request is a defensive posture; PCMA's simultaneous argument that PBM reform serves pharma interests and that further transparency rules are duplicative reveals strategic tension
  • Manufacturers with 340B exposure — Appropriations rider, state litigation fund, and revived pricing case create multi-front defense obligations; the unilateral rebate model strategy faces both legislative and judicial closure

Neutral but pivotal:

  • Drug Channels Institute / DCLF attendees — March 24 Economic Report will set the analytical baseline for how the NPDC transition reshapes every participant's economics; the $751B pharmacy market data validates GLP-1 as the defining category for channel strategy
  • DOL — March 31 comment deadline will determine whether commercial-market PBM transparency advances, stalls, or is folded into CAA 2026 implementation; the outcome shapes whether any market segment remains opaque
  • Samsung Bioepis — 20-product biosimilar target by 2030 (Dupixent, Tremfya, Enhertu, Ocrevus, Taltz) would make it the most prolific next-generation biosimilar developer; execution against Sandoz commercialization partnership is the key variable