11.5.2026
SL Insight Newsletter #34
KFM: Swiss clawbacks weigh on the U.S. market
Marcel Boller
The Council of Economic Advisers’ report dated May 5, 2026, defines the MFN reference price as a net price, explicitly “including portfolio-wide clawbacks such as the UK Voluntary Scheme for Branded Medicines Pricing and Access (VPAG).” This definition also effectively covers Swiss cost-based pricing models (KFM).
What does this mean for Switzerland?
A KFM has two traditional functions: addressing the budget impact argument and protecting the visible list price from international benchmarking. From the perspective of the MFN architecture, this logic is reversed. A KFM is an additional lever that reduces the U.S. price anchor
While the KP2 reform does strengthen the confidentiality of net prices and promotes the use of KFM, the federal government is thereby incentivizing precisely the mechanism identified as a "clawback" in the CEA report.
