The Colorado Prescription Drug Affordability Board (PDAB) set the first Upper Payment Limit (UPL) for Enbrel at $600 per syringe on October 3, 2025, to take effect in 2027. The Enbrel UPL in Colorado was based on the Medicare maximum fair price (MFP).
UPLs present opportunities for payers and financial challenges for pharmacies, leaving manufacturers with difficult choices. Lower per-script reimbursement to pharmacies may lead pharmacies/specialty pharmacies to seek a state-specific contract with manufacturers.
CRA’s Life Sciences consultants Chris Nüesch and Laura Jenkins analyze the Colorado PDAB timeline and the key unknowns surrounding the implementation of Colorado’s UPL for Enbrel.


