MDH Releases Inaugural List of Prescription Drugs of “Substantial Public Interest”

June 27, 2024

On June 26, the Minnesota Department of Health (MDH) released an initial list of drugs that are priced significantly higher than their listed cost.  

The list includes drug families with drug products that meet two criteria: 1) the average claims paid amount was more than $100; and 2) the average claims paid amount is 125% of the manufacturer’s list price as of the date in which the claim was incurred.   

MDH estimates that 37% of all retail drug products dispensed for commercially insured Minnesotans, per the Minnesota All Payer Claims Database (APCD) in 2022, meet these criteria. This amounts to annual spending of $345 million over manufacturer list prices and represents 54% of the total amount paid for these drug products before rebates. 

The inaugural list features 10 drug families containing a total of 364 drug products from 76 manufacturers. These 10 drug families include all pharmaceutically equivalent drug products on the market for comparison, with drug products across all strengths and package sizes. MDH selected the drug families having the greatest absolute difference between the total claims paid amount and the total list price. The diversity of drug families on this list will allow MDH to better understand the prescription drug supply chain, including intermediary price increases and rebate dynamics. 

The list is the result of legislation passed in 2023 by the Minnesota Legislature. Called the Prescription Drug Price Transparency Act, the law requires new reporting from drug manufacturers, pharmacy benefit managers (PBMs), wholesalers, and pharmacies on drugs of substantial public interest.  

Reporting entities will have approximately 90 days to report (notifications will be sent 30 or more days after the list release date; reports are due 60 days after notifications are sent).  

MDH will continue to release updates on implementation on the MDH Rx Price Transparency website. For questions, please email health.rx@state.mn.us 

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