On May 12, 2025, President Trump signed an Executive Order (“EO” or “Order”) “Delivering Most-Favored-Nation Prescription Drug Pricing to American Patients” aimed at significantly reducing U.S. prescription drug prices by aligning them with the lowest prices paid by other developed nations. According to the EO, drug manufacturers “deeply discount their products to access foreign markets and subsidize that decrease through enormously high prices in the United States.” Seeking to rectify this “egregious imbalance,” the EO announced the following policy: “Americans must therefore have access to the most-favored-nation price for these products… [and] should drug manufacturers fail to offer American consumers the most-favored-nation lowest price, [the] Administration will take additional aggressive action.”
Jonathan M. Phillips
Partner, Washington, D.C.
+1 202.887.3546
Jonathan Phillips is a partner in the Washington, D.C. office of Gibson, Dunn & Crutcher, where he is a member of the firm’s litigation department and Co-Chair of the FDA and Health Care Practice Group and False Claims Act/Qui Tam Defense Practice Group. A former DOJ Trial Attorney, his practice focuses on FDA and health care enforcement, compliance, and litigation, as well as other white collar enforcement matters and related litigation. Mr. Phillips is ranked nationally as a leading False Claims Act practitioner by Chambers USA.