PhRMA submitted comments on the Centers for Medicare & Medicaid Services’ Medicare Drug Price Negotiation Program: Draft Guidance, Implementation of Sections 1191 – 1198 of the Social Security Act for Initial Price Applicability Year 2027 and Manufacturer Effectuation of the Maximum Fair Price (MFP) in 2026 and 2027. We are disappointed that after more than a year of hearing concerns and feedback from stakeholders, CMS has largely stayed its course in the Guidance for IPAY 2027. In this letter, we articulate our core concerns with CMS’ Draft Guidance for IPAY 2027.