The 2026 Federal Market Access Reset

Bottom Line:

In a rapidly evolving federal healthcare environment, manufacturer success in 2026 hinges on an organization’s ability to execute against five critical catalysts that are currently reshaping the market landscape.

The federal healthcare landscape - encompassing the Department of Veterans Affairs (VA) and the Department of Defense (DoD) - is entering a period of significant structural transition. Several regulatory and administrative events will change how manufacturers access this market.

VHA reorganization will lead to national policy standardization

In December 2025, the VA announced a comprehensive reorganization of the Veterans Health Administration (VHA) management structure, which involves consolidation of the 18 Veterans Integrated Service Networks (VISNs) into 5 centralized regions. This change is expected to realign all clinical policy to the headquarters level.

Impact: The restructuring explicitly aims to ensure consistent policy across all VA medical facilities and greatly reduce the clinical autonomy that previously allowed for local formulary variances. Instead, the VA will evolve into a top-down model with tight standardization.

2026 Strategic Imperative: Manufacturers should accelerate transitioning now from a field-heavy regional model to a national accounts focus.

The DHA BAP "thaw" will clear the existing implementation backlog

Throughout 2025, the DoD’s Beneficiary Advisory Panel (BAP) faced a membership vacancy that created an administrative hold on finalizing many P&T Committee recommendations, since the BAP is legally required to review P&T Committee recommendations before the DHA Director can finalize them.

Impact: With the BAP expected to be fully re-seated in early 2026, a year’s worth of formulary decisions will be implemented and a high volume of tier shifts, criteria updates, and new product entries will reach the TRICARE system simultaneously.

2026 Strategic Imperative: Manufacturers must prioritize operational readiness to ensure they can execute at scale to navigate a rapid-fire rollout that will see multiple quarters of previously deferred formulary changes go live simultaneously.

VHA Community Care changes will reflect Third-Party Administrators’ contractual performance mandates

The VA’s intends to shift from single regional managers to competitive, managed care style oversight through a Multiple-Award Indefinite Delivery/Indefinite Quantity (IDIQ) contract structure, which will allow the VA to dynamically shift work between multiple Third-Party Administrators (TPAs) based on performance.

Impact: While the community care authorizations expanded to 12 months for 30 specialties benefits manufacturers, it will simultaneously increase the number of Third-Party Administrators (TPAs). Competitively awarded task orders are expected to be structured to achieve specific VA goals, enforce desired clinical outcomes, and/or financial savings.

2026 Strategic Imperative: Manufacturers must treat these TPAs as distinct payers and understand the specific protocols for navigating each entity's commercial-style approach under a federal health system.

PACT Act funding surge for the Toxic Exposures Fund.

The signed FY2026 budget allocated over $50 billion for the mandatory Toxic Exposures Fund (TEF) associated with the PACT Act, which is a dramatic increase over 2025.

Impact: The TEF budget is statutorily insulated and represents a stable, high-priority funding channel.

2026 Strategic Impact: Manufacturers in relevant therapeutic areas should bridge the gap between their clinical and HEOR data to explicitly support the PACT Act’s core mission. It is important to position a therapy as an essential clinical pathway for improving outcomes in TEF-eligible Veteran populations.

New Non-FAMP Calculations

The VA National Acquisition Center (NAC) confirmed that Inflation Reduction Act (IRA)-negotiated prices for Medicare Part D will be included in Non-Federal Average Manufacturer Price (non-FAMP) calculations.

Impact: Because non-FAMP is the basis for the Federal Ceiling Price (FCP), the downward pressure from Medicare negotiation will impact this part of the federal market as well.

2026 Strategic Imperative: Manufacturers must start the process of calibrating their 2027 federal market-access strategy to account for the downward pricing pressure this change will exert.