Editor’s Note: The attached comment letter was submitted to the Office of the U.S. Trade Representative (USTR) on June 27, 2025.
Schaeffer Center Scholars commented on USTR’s May 30, 2025, request for information regarding foreign acts, policies, or practices that result in American patients paying a disproportionate amount for global pharmaceutical research and development.
The researchers recommended options to confront foreign countries’ use of quality adjusted life years (QALYs) in determining prices. This discriminatory practice systematically undervalues treatments for vulnerable populations, artificially suppresses drug prices below American standards of fair market value and forces American patients to subsidize global healthcare systems.
USTR should consider these policy options:
- Initiate Section 301 investigations into countries that systematically use QALYs to suppress pharmaceutical prices below American standards of fair market value
- Negotiate bilateral agreements requiring foreign countries to abandon or modify QALY-based pricing methodologies
- Pursue World Trade Organization dispute resolution where QALY-based practices constitute discriminatory treatment of U.S. pharmaceutical exports
- Implement targeted tariffs or trade sanctions against countries that refuse to abandon discriminatory QALY practices
Read the full comment letter here.
