Don’t wait on CMS-1832-P: Prepare now for Maximum Fair Price (MFP), bundling and bona fide fees. The CY 2026 Proposed Rule (CMS-1832-P) may still be in draft form, but manufacturers can’t afford to treat it as hypothetical. History shows that once CMS signals reform, it’s only a matter of time before enforcement follows.
Waiting until the rule is finalized means lost time and revenue. Proactive pharmaceutical companies who act now will preserve market access and pricing integrity and reactive companies will face reduced revenue, increased risk and potential CMS scrutiny.
The changes to MFP, bundled discounts and bona fide service fees will reshape how Average Sales Price (ASP) is calculated, reported and supported. Manufacturers who delay risk will be scrambling against deadlines, facing compliance exposure and absorbing unexpected reimbursement penalties.
Preparedness is no longer optional — it’s imperative. Those who start building systems, documentation and cross-functional coordination now will be the ones who preserve market access and pricing integrity later. Don’t get caught unprepared.
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