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Value-based drug agreements are easier when drug manufacturers and payers follow FDA communication guidelines

When pharmaceutical manufacturers share clinical and economic data about their products in the pipeline, payers can prepare their budgets and formularies to launch value-based drug pricing arrangements as soon as a new treatment receives FDA approval. Pre-approval data sharing between manufacturers and payers gives patients quicker access to newly approved treatments.

 

As the healthcare system in the U.S. continues its transition from fee-for-service to value-based care, the sharing of healthcare economic information (HCEI) is becoming increasingly important to pharmaceutical manufacturers and healthcare payers seeking to enter value-based drug pricing arrangements.

In the past, drug manufacturers were hesitant to share HCEI and other pre-approval information with payers because regulations were unclear about the legal limits of this type of communication. But payers want HCEI from drug manufacturers for planning, formulary design, budgeting, and purchasing decisions. And lawmakers want to eliminate legislative barriers that inhibit the sharing of HCEI and the increased adoption of value-based healthcare.

The history of legislation surrounding manufacturer/payer communications

Policymakers and regulators, like the Food and Drug Administration (FDA), recognize the importance of big data and the sharing of HCEI for promoting value-based payment arrangements. Their first attempts to remove the legislative barriers to the exchange of HCEI between drug and device manufacturers and population healthcare managers did not produce the desired effects.

The first U.S. federal consumer protection law, the Food and Drugs Act, was enacted in 1906. This law’s consumer protections and law enforcement capabilities were strengthened by the 1938 Food, Drug, and Cosmetic Act (FD&C). Section 502(a) of the FD&C introduced and defined HCEI, giving the pharmaceutical industry their first instructions about what kind of economic data promotion could be communicated and with whom. But manufacturers refused to share information, fearing the penalties of accidentally disseminating off-label information.

Section 114 of the FDA Modernization Act (FDAMA) of 1997, amended FD&C Section 502(a) and provided a safe harbor for HCEI sharing. But manufacturers continued to resist sharing economic data because they felt the guidelines were still too vague about some topics, such as the definition of reliable scientific evidence and who was authorized to receive HCEI. The FDA failed to issue guidance on how to interpret the law.

The industry-wide push towards value-based care after the Affordable Care Act passed made clarification of Section 114 a priority again. In 2016, policymakers issued clarifying guidance about communications and transparency of HCEI, both pre- and post- FDA approval. The 21st Century Cures Act, Section 3037 further defined what types of HCEI and analyses could be used for drug promotion and to whom the HCEI should be communicated. The FDA published a draft payer guidance document in 2017 and then final guidance documents in 2018 suggesting ways to operationalize communications between pharmaceutical manufacturers and payers.

Current FDA guidance

An FDA press statement from June 2018 emphasizes that the 2018 guidance documents are meant to help pharmaceutical manufacturers provide payers with truthful, non-misleading background and contextual information about their products. Furthermore, manufacturers are encouraged to share both clinical data and HCEI payers need to make informed decisions about formulary management, cost-effectiveness, and reimbursement; this may be more and different data than the safety and efficacy data submitted by the manufacturer to the FDA for drug approval decisions. Rebate management for payer is also a critical aspect of this process, enabling payers to optimize their strategies for cost containment and value-based care.

The guidance, Drug and Device Manufacturer Communications with Payors, Formulary Committees, and Similar Entities–Questions and Answers, expands upon the sources of scientific evidence for HCEI as defined under Section 502(a). And the guidance clarifies who can receive HCEI, including public and private sector payers, formulary committees, technology assessment panels, third-party administrators, and other multidisciplinary parties.

This first guidance also addresses manufacturers’ communications with payers regarding unapproved uses of FDA-approved products. The FDA does not object to the sharing of this type of information as long as the manufacturer makes it abundantly clear in its communications what uses the product is not approved for.

The second guidance introduced in the FDA press statement is titled Medical Product Communications That Are Consistent With FDA-Required Labeling–Questions and Answers. It pertains to information not included in a drug’s labeling but information that a manufacturer may want to share with payers. Examples can include data from pre- and post-market studies or surveillance of patient compliance that can affect the measurement of a drug’s benefits to health outcomes in value-based contracts. (The first guidance offers safe harbor for communications related to the negotiations or implementation of value-based drug pricing agreements.)

Timing of information exchanges

Payers prefer to receive information regularly from manufacturers during the latter part of the FDA drug approval process. Annual budgets and formulary planning are more difficult to forecast if payers don’t have data in advance to prepare for the coverage of a new drug. Payers are more likely to make a newly approved treatment available to patients without delay when manufacturers share the clinical data and HCEI needed to make formulary and pricing decisions during pre-approval.

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Under the FDA’s accelerated approval process, therapies sometimes become available to patients even before the publication of clinical trial data is complete. Payers say, ideally, they would like clinical and HCEI data about new products 12 to 18 months before the projected FDA approval date.

Many manufacturers wait to begin communications with payers until just 6 to 12 months before their product’s expected approval date. Recognizing the importance of HCEI in negotiating value-based drug pricing arrangements, some manufacturers have included HCEI in their FDA product dossier and promotional materials for payers.

The FDA guidance recommends increased transparency about cost data, including price range, price parity with competitors, price premiums, discounts, and inflation adjustments. Some manufacturers and payers prefer to wait for final clinical trial data before discussing pricing. Post-approval data-sharing of real-world evidence must continue between manufacturers and payers to implement value-based drug pricing agreements.

The Lyfegen solution

With most regulatory barriers removed and value-based contract communications exempted from FDA reporting, policymakers hope to see an increase in value-based drug pricing arrangements. Manufacturers and payers can partner with third-party vendors like Lyfegen to employ technology that facilitates easy, continued data-sharing for innovative pricing agreements.

Lyfegen is an independent, global analytics company that offers a value-based contracting platform for healthcare insurances, pharma, and medtech companies wanting to implement value-based drug pricing arrangements with greater efficiency and transparency. The Lyfegen Platform collects real-world data and uses intelligent algorithms to provide valuable information about drug performance and cost.

By enabling the shift away from volume-based and fee-for-service healthcare to value-based healthcare, Lyfegen increases access to healthcare treatments and their affordability.

To learn more about our services and the Lyfegen Platform, book a demo.

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Managing drug rebates effectively is critical for ensuring financial sustainability while maintaining patient access to essential treatments. With the rising complexity of rebate agreements and the increasing administrative burden on payers and healthcare systems, selecting the right drug rebate management solution is more important than ever. In this blog, we’ll explore key factors to consider when choosing a solution and how Lyfegen’s advanced rebate management platform can streamline the process and optimize financial performance.

The Growing Complexity of Drug Rebate Management

The pharmaceutical industry is shifting towards more intricate pricing and reimbursement models, with value-based agreements, outcome-driven pricing, and performance-based contracts becoming the norm. As a result, healthcare payers and providers need robust systems to accurately track, claim, and optimize rebates.

Traditional rebate management processes—often manual and reliant on spreadsheets—are inefficient and prone to errors, leading to missed rebate opportunities and financial leakage. A modern rebate management solution should offer automation, transparency, and scalability to address these challenges effectively.

Key Features to Look for in a Drug Rebate Management Solution

When evaluating rebate management solutions, payers and healthcare organizations should prioritize the following features:

1. Comprehensive Contract Compliance and Accuracy

Ensuring that all rebates are accurately calculated and claimed according to contract terms is fundamental. Many organizations miss out on significant rebate revenue due to errors in claim tracking, missed deadlines, or lack of visibility into agreement terms. A robust rebate management solution should offer real-time tracking, validation checks, and automated claim submissions to ensure full compliance and minimize financial losses.

2. Automation to Reduce Administrative Burden

Manual rebate processing is time-consuming, resource-intensive, and susceptible to human error. Automating rebate management can significantly reduce administrative costs while improving efficiency and accuracy. The right solution should provide automated data input, mapping, reconciliation, and dispute resolution, ensuring that rebates are processed smoothly without manual intervention.

3. Centralized Agreement Management

Managing multiple rebate agreements across different pharmaceutical manufacturers, products, and therapeutic areas can be overwhelming. A centralized platform allows users to track, update, and analyze agreements in one place, offering a structured repository for easy access to contract details, claims history, and invoicing records. This reduces the risk of mismanagement and enhances visibility across departments.

4. Secure and Transparent Data Sharing

Effective rebate management requires seamless collaboration between payers, manufacturers, and internal teams. A robust solution should offer secure data-sharing capabilities while maintaining privacy compliance. Role-based access control, encrypted transmissions, and audit trails help ensure that sensitive financial and patient data is protected while enabling necessary stakeholders to access relevant information when needed.

5. Forecasting and Analytics for Better Decision-Making

Beyond rebate tracking, a solution should provide actionable insights through analytics and forecasting. Organizations need visibility into past trends and future rebate expectations to make informed financial decisions. A comprehensive platform should offer reporting dashboards, real-time financial modeling, and historical data comparisons to support strategic planning and contract negotiations.

Why Lyfegen?

Choosing the right rebate management solution is not just about compliance and automation—it’s about unlocking financial opportunities and maximizing the impact of negotiated agreements. Lyfegen’s Rebate Analytics Platform (ARA) is designed to:

  • Ensure full contract compliance by accurately identifying and claiming all eligible rebates.
  • Reduce administrative burden by automating rebate calculations, validation, and dispute resolution.
  • Centralize agreement management with a secure, intuitive platform.
  • Facilitate transparent data-sharing with built-in security measures.
  • Provide robust analytics and forecasting for data-driven decision-making.

With automated data input, mapping, and validation, Lyfegen's ARA streamlines rebate calculations and dispute resolution. Customers using Lyfegen’s platform have identified up to 30% of missed rebates while reducing administrative workload by up to 97%.Additionally, Lyfegen’s solution offers real-time simulations, predictive modeling, and scenario comparisons, allowing payers and healthcare organizations to proactively assess financial impacts before finalizing agreements.

The Time to Act Is Now

With increasing pressures on healthcare budgets and the complexity of drug rebate agreements, organizations cannot afford inefficiencies in rebate management. Lyfegen’s solutions empower payers and healthcare organizations to simplify the process, recover lost revenue, and optimize financial performance.

Book a demo today to see how Lyfegen’s rebate management platform can transform your approach to drug contracting and financial optimization.

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Basel, Switzerland –28, January 2025 -  Lyfegen, a global innovator in drug market access, pricing, and rebate management, has announced a transformative collaboration with EVERSANA®, a leading provider of global commercial services to the life sciences industry, to revolutionize drug pricing and access through artificial intelligence-driven insights.  

By combining data and information from the global pricing and market access platform, NAVLIN by EVERSANA®, with Lyfegen’s Public Drug Agreement Library, the two organizations will harness cutting-edge AI to empower market access and pricing professionals and payers with actionable insights. The joint agreement marks a key step in tackling rising drug costs and improving patient access globally.

Simplifying Complexity with AI

Drug pricing and access are increasingly difficult to navigate, with healthcare payers and pharmaceutical companies facing inefficiencies, missed opportunities, and delays in delivering therapies to patients.

The collaboration combines two leading platforms to address these challenges:

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Together, these tools deliver a 360-degree view of pricing trends and access frameworks, enhanced by AI-driven capabilities. This integration helps users:

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Driving Smarter and Fairer Decisions  

Together, Lyfegen and EVERSANA will empower market access teams to make smarter, faster, and more equitable decisions. By combining AI-driven insights with robust data, payers and pharmaceutical companies can reduce inefficiencies and ensure patients receive timely access to life-saving therapies.
 

“Together with Lyfegen we can harness the power of AI to address one of the biggest challenges in healthcare—helping patients get timely access to life-saving medicines,” said Jim Lang, CEO, EVERSANA. “By uniting our expertise and our global pricing innovations, we have the opportunity to deliver a solution that simplifies decision-making and improves access in healthcare systems worldwide.”

A Vision for the Future of Drug Access

The healthcare industry is rapidly adopting AI to drive efficiency and innovation. This partnership positions Lyfegen and EVERSANA at the forefront of this transformation, enabling stakeholders to overcome affordability and access challenges.

“Our mission at Lyfegen has always been to create a more sustainable and equitable healthcare environment,” said Girisha Fernando, CEO of Lyfegen. “Through this partnership with EVERSANA, we are taking a giant step toward that future. By integrating EVERSANA’s price and access data into our combined offerings, we’re not just solving today’s challenges—we’re building a foundation for a smarter, more efficient drug access and pricing landscape.”

About Lyfegen

Lyfegen is an independent provider of rebate management software designed for the healthcare industry. With the world’s largest repository of drug access agreements and a powerful pricing simulator, Lyfegen helps payers and pharma implement and optimize rebates, reduce administrative effort, and understand financial impacts. Founded in 2018, Lyfegen is headquartered in Basel, Switzerland. Learn more at Lyfegen.com or connect with us on LinkedIn.  

About EVERSANA

EVERSANA® is a leading independent provider of global services to the life sciences industry. The company’s integrated solutions are rooted in the patient experience and span all stages of the product life cycle to deliver long-term, sustainable value for patients, prescribers, channel partners and payers. The company serves more than 650 organizations, including innovative start-ups and established pharmaceutical companies, to advance life sciences solutions for a healthier world. To learn more about EVERSANA, visit eversana.com or connect through LinkedIn and X. 

Media Contacts

For Lyfegen

marketing@lyfegen.com  

For EVERSANA

Matt Braun

Vice President, Corporate Communications

matt.braun@eversana.com  

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