The DoD BAP Freeze: What It Means for Federal Market Access

The Defense Health Agency’s Benefits Advisory Panel (BAP) has long served as a gatekeeper in the military health system’s formulary decision process. However as of today, the BAP remains effectively sidelined. A Department of Defense directive has placed a hold on all Federal Advisory Committees, leaving the BAP inactive until further notice.

Why This Matters

For manufacturers seeking formulary placement within the Military Health System, the implications are significant. The Pharmacy and Therapeutics (P&T) Committee continues its core work of evaluating evidence and issuing recommendations, but under statute no change can be finalized without BAP review. The result is a bottleneck: the system can generate recommendations but cannot execute them.

This can translate into delayed patient access, slowed contracting volume recognition, and uncertainty in launch and class review planning. Manufacturers that had anticipated the business impact of advantageous formulary access now face indefinite delays, complicating forecasting and resource allocation.

The Access Gap

The pause not only stalls new therapies from advancing favorable access and utilization management, it also highlights how dependent federal market access is on governance structures and processes. Until the Secretary of Defense reinstates the BAP, manufacturers remain in a holding pattern, unable to move products to final formulary decisions regardless of clinical or economic merit.

What Manufacturers Should Do Now

To navigate this disruption, forward-thinking companies can use this window to strengthen positioning and prepare for rapid action once the freeze is lifted. Priorities include:

• Reassess federal launch and class review timelines: Build flexibility into planning, recognizing the backlog that will emerge.

• Strengthen clinical and value narratives: Ensure evidence packages and health economic models are specific to DoD and optimized for swift pull-through.

• Deepen stakeholder engagement: A wide range of stakeholders remain influential, even absent BAP activity.

• Explore interim channels: Other segments and care pathways that continue to shape prescribing and access.

  
  

The federal market rewards persistence, preparation, and adaptability. While the BAP hold has created a pause, it will eventually lift. The advantage will go to those ready to act decisively, seizing formulary opportunities and leveraging federal influence that extends well beyond the Military Health System.