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A quick update before we jump in — The Trade Desk ($TTD), which was up 30% after our buy call in June, just reported its earnings and is down 28% in pre-market. We will be covering the earnings and its long-term impact in detail tomorrow (available only for paid subscribers).

U.S. healthcare and pharmaceutical stocks are experiencing their worst performance in decades. Healthcare’s valuation discount to the S&P 500 is now nearly at its widest in 30 years, and most companies are trading at half the P/E of the S&P 500.

Drawdown figures on some of these household names are astonishing:

  • Eli Lilly: 33%

  • Merck & Co: 38%

  • Pfizer: 52%

  • Novo Nordisk: 66%

Healthcare ETFs have now seen 12 consecutive months of net outflows, and the outflow in July was more than any other sector, according to State Street. To put the drawdown in perspective,

The total market value of the S&P 500 healthcare is now $4.8 trillion, which is only 10% more than Nvidia’s $4.4 trillion.

This has naturally attracted a lot of value investors who believe that the bad news is priced in and the market is due for a pullback.

While we agree with the overall sentiment (as we highlighted with our GLP-1 investment basket), there is something that could turn these bargains into value traps.

Trump’s Most Favored Nation (MFN) proposal would force Medicare to pay no more than the lowest price that peer nations pay for the same drugs. U.S. drug prices for many medications are 4–5 times those in peer-developed markets.

While the proposal is logical, if it’s enforced in its current form, it will be catastrophic for most of these companies. Given the compressed valuations, deep drawdowns, and constant regulatory overhang, let’s dig into:

  1. What’s actually in the Most Favored Nation Proposal?

  2. Implementation timelines

  3. Which companies have the highest exposures?

  4. What happened when Trump tried MFN in 2020?

  5. Our take

  6. Is it time to invest in Healthcare/Pharmaceuticals?

Most-Favored-Nation prescription drug pricing

It started with this May 12th executive order from President Trump. It directs the U.S. to secure a most-favored-nation (MFN) price on prescription drugs. Simply put, the aim is that Americans should pay no more than the lowest price in comparable developed countries.

Just focusing on the key aspects,

  • The Department of Health and Human Services (HHS) had to communicate these new prices to drugmakers within 30 days of May 12th, 2025.

  • DOJ & FTC are directed to pursue antitrust enforcement against anti-competitive practices by pharmaceutical companies.

  • The order claims that Americans fund 3/4th of global Pharma profits as we are paying 3x other nations’ prices.

After the administration engaged with manufacturers on MFN pricing, the proposals fell short. Last week, on July 31st, the White House sent letters to 17 pharma companies laying out specific MFN paths.

The letter had four demands:

  1. Give every Medicaid patient the MFN price (lowest among peer developed nations).

  2. Pledge not to sell new drugs abroad at better prices than in the U.S.

  3. Offer direct-to-patient sales at no higher than MFN.

  4. Use trade policy to lift foreign prices.

Implementation timelines

September 29th will be the deadline for companies to update to MFN pricing. If not, Trump has said that he would "deploy every tool in our arsenal to protect American families from continued abusive drug pricing."

Till now, none of the companies has responded to the letter. It makes sense, as it’s still very early in the 60-day window, and pricing teams will likely drag their feet until the White House makes its next move.

Companies with the highest exposure

The 17 companies that received the letters were

While all these companies have something to lose by the MFN implementation, there are a few firms that will be hit the hardest.

1. Merck & Co ($MRK)

Merck was already in a deep drawdown before MFN. They are very reliant on U.S. sales of Keytruda (a top-selling cancer immunotherapy). Keytruda’s price in the U.S. is substantially higher than abroad, and it currently has no biosimilar competition (making it an ideal target for MFN). Merck gets an estimated ~45-50% of its revenue from the U.S., but a larger share of profit (due to price differentials).

2. Eli Lilly ($LLY) and Novo Nordisk ($NVO)

Both are part of our GLP-1 portfolio and are among the leading GLP-1 drugs for diabetes and obesity. U.S. insulin prices have been notoriously high compared to those in the rest of the world. Even their weight loss drugs, Ozempic and Wegovy, are both considerably cheaper in Europe. Both firms derive roughly ~50% or more of sales from the U.S. market and stand to lose significant revenue if forced to sell at MFN prices.

3. Bristol Myers Squibb ($BMY) and Pfizer ($PFE)

These partners co-market Eliquis, a blockbuster blood thinner with no generic due until 2028. Eliquis has been a significant cash cow in the U.S. Any mandate to sell at the lowest global price would substantially reduce its U.S. profit.

p.s. — This is just a preliminary list based on a glance at their product mix. Deeper due diligence coming soon.

What happened the last time around?

This is not the first time the Trump administration has attempted to implement most-favored-nation pricing. Back in November 2020, it was announced that Medicare drugs would come under the MFN model starting in January 2021.

But just next month, it was blocked by a Judge for skipping APA notice, followed by a nationwide preliminary injunction. After this, the new Biden administration did not try to salvage a model that was legally vulnerable and operationally disruptive.

Our take & a healthcare basket?

The concerns are overblown and may have created a buying opportunity.

  • While the second time around, the Trump administration has set up a negotiation timeline directly addressing the core defect from the 2020 debacle. However, this does not mean that the courts will ignore other aspects, such as government overreach and irreparable harm, which they have previously accepted.

  • Anything more than a pilot will need congressional approval, which makes it a long-drawn-out process (with low chances of success).

  • Of the total U.S. retail prescription drug spend, Medicaid is estimated to be roughly 11%. So even if implemented, the overall revenue impact will only be on <10% of most companies’ total revenue (The spillover effect on commercial and 340B prices has to be seen). Doing a very basic back-of-the-envelope calculation,

    • 50% price cut on meds

    • Medicaid @ ~11% of U.S. retail Rx

    • 50% revenue from the U.S.

      • Global revenue impact => 50% x 11% x 50% = 2.75% total drop (assuming no increase in sales/repricing in Europe)

JP Morgan had an interesting finding where on average, the S&P 500 returned only 4% in the next 12 months if you invested when the consumer sentiment was at its peak, whereas if you invested when the consumer sentiment was at its lowest, over the next 12 months, your average return was 24.9%!

A 6x increase in returns just by investing when everyone else was skeptical to do so.

Healthcare is going through a similar situation where consumer sentiment is now at the lowest it has ever been. While its tough to invest in a situation like this given the uncertainties, it’s exactly these setups that will provide the most return if we can stomach the volatility.

Next week, we will be building (and investing our own capital) into a healthcare basket. The report will be exclusive to Rebound Capital paid subscribers.

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