Evaluating the Medicaid Multiple Best Prices Provision as a Pathway for Value-Based Purchasing

This policy brief examines stakeholder perspectives on the Medicaid Multiple Best Prices (MMBP) provision and its role in supporting value-based purchasing (VBP) arrangements for drugs. The MMBP pathway was intended to address an important Best Price-related barrier to VBP arrangements for drugs by allowing manufacturers to report multiple Best Prices associated with qualifying VBP arrangements offered to all state Medicaid programs. Findings from interviews with state Medicaid programs and drug manufacturers suggest that while the MMBP pathway may reduce certain Best Price barriers, it has not yet become a widely used pathway for state Medicaid drug VBP arrangements. Both state Medicaid organizations and manufacturers identified several factors limiting the use of MMBP, including operational complexity, limited state capacity, uncertainty around data collection and outcome measurement, the challenge of adapting commercially designed arrangements to Medicaid program needs, and legal and regulatory barriers, including 340B duplicate discount concerns. Instead, states interviewed generally reported relying on other contracting mechanisms, including traditional supplemental rebate agreements (SRA), state-specific VBP supplemental rebate agreements, and participation in the Cell and Gene Therapy (CGT) Access Model, rather than adopting arrangements through the MMBP pathway. Taken together, these findings suggest that without additional policy or operational support, the MMBP pathway may function more effectively as a Best Price reporting mechanism for manufacturers than as a practical contracting pathway for state Medicaid programs.