Infographics

Upper Payment Limits (UPLs) explained

December 15, 2025
Charles River Associates Pill Production Line

State prescription drug affordability boards (PDABs) reshape the pharmaceutical pricing landscape. Upper Payment Limits (UPLs) are caps on the reimbursement rates that payers pay to pharmacies, providers, and sites of care for drugs deemed “unaffordable” by a state PDAB.

Regulatory shifts create new challenges for pharmaceutical stakeholders. Four states now have PDABs empowered to set UPLs for public payers, and three states can now extend these limits beyond public payers to include commercial payers as well.

CRA’s life sciences consultants Chris Nüesch and Laura Jenkins analyze the supply chain implications and strategic responses in this infographic. Their comprehensive analysis examines the various methodologies states are considering—from international reference pricing to therapeutic class benchmarking—and their cascading effects across the entire value chain.

Key contacts