The Trump insulin executive order signed on April 15, 2025, revives a narrow rule from his first term: federally funded community health centers that buy insulin at deep 340B discounts must pass those discounts through to certain low-income patients, charging no more than the acquisition cost plus a small administrative fee.1Federal Register. Lowering Drug Prices by Once Again Putting Americans First It applies only to a specific slice of patients at a specific type of clinic, and as of mid-2026 the implementing rule is still being written. For most people asking what they will pay for insulin, the answer comes from other programs.
What the 2025 Order Actually Requires
Executive Order 14273, “Lowering Drug Prices by Once Again Putting Americans First,” gives the Department of Health and Human Services 90 days to condition future Section 330(e) grants to Federally Qualified Health Centers on a pricing requirement. FQHCs that dispense insulin or injectable epinephrine would have to make those drugs available to eligible patients at or below the 340B acquisition cost, plus a minimal administrative fee.1Federal Register. Lowering Drug Prices by Once Again Putting Americans First
FQHCs are community clinics that receive federal grants and serve predominantly low-income patients. They already buy outpatient drugs at steep discounts through the 340B Drug Pricing Program. The order’s premise is that when a clinic buys insulin cheaply through 340B, the patient who needs it should get that same discounted price rather than paying retail.
Eligibility is limited to three groups of patients:
- People with high cost-sharing requirements for insulin
- People with large unmet deductibles
- People with no health insurance at all
The scope is narrow by design. It reaches only FQHCs receiving Section 330(e) grants, only insulin and injectable epinephrine, and only patients who fit one of those three financial categories. It does not touch retail pharmacies, hospital pharmacies, or any drug purchased outside the 340B system.
Why the First Version Never Took Effect
Trump signed the original version, Executive Order 13937, on July 24, 2020. HHS published a final rule on December 23, 2020, with an effective date of January 22, 2021 — two days after President Biden took office.2Federal Register. Implementation of Executive Order on Access to Affordable Life-Saving Medications
The Biden administration froze the rule and then moved to rescind it. On June 16, 2021, HHS published a proposed rescission, arguing the requirement would strain health center resources without meaningfully expanding insulin access.3Federal Register. Proposed Rescission of Executive Order 13937 – Executive Order on Access to Affordable Life-Saving Medications Health center organizations had raised the same objection: tying grant funding to point-of-sale pricing requirements pulls resources away from dental care, mental health, and chronic disease management, without changing costs for most patients. The 2025 version faces the same objections, and HHS rulemaking remains ongoing.
What the Order Does Not Cover
If you don’t get your insulin at an FQHC, the executive order does not change your price. It doesn’t cap what pharmacies can charge. It doesn’t set what insurers must cover. It doesn’t apply to Medicare, Medicaid, or commercial insurance directly. Patients enrolled in Medicare or Medicaid also aren’t the population the order targets, since they aren’t uninsured and typically don’t face the high cost-sharing or deductible exposure the order addresses.
The order is one tool in a policy area where the meaningful price protections for most people come from elsewhere.
What Actually Determines Your Insulin Cost in 2026
Your out-of-pocket cost for insulin depends almost entirely on what kind of coverage you have.
If You Have Medicare
You pay no more than $35 per month for each covered insulin product, and the Part D deductible does not apply to covered insulins.4Centers for Medicare & Medicaid Services. Anniversary of the Inflation Reduction Act – Update on CMS Implementation This is federal law under the Inflation Reduction Act, effective January 1, 2023, for Part D and July 1, 2023, for insulin used in pumps covered under Part B.5U.S. Department of Health and Human Services. Insulin Affordability and the Inflation Reduction Act – Medicare Beneficiary Savings by State and Demographics A three-month supply is capped proportionally, at $105.6Medicare.gov. Insulin The broader Part D annual out-of-pocket cap is $2,000 in 2025 and $2,100 in 2026.
None of this depends on the executive order, and none of it can be undone by one.
If You Have Commercial Insurance in a State With a Copay Cap
Twenty-nine states and the District of Columbia have enacted their own insulin copay caps for state-regulated commercial insurance plans. The limits range from $0 per month in New York up to $100 in states like Alabama and Colorado, with most falling between $25 and $35 for a 30-day supply.
These caps apply to state-regulated plans: individual coverage, small-group coverage, and fully insured employer plans. If your employer self-funds its health plan, it is generally regulated under ERISA at the federal level, and state copay caps typically don’t reach it. That’s the biggest gap in the state law framework.
If You Have Commercial Insurance Without a State Cap
Manufacturer programs can bring your monthly cost to $35. In March 2023, Eli Lilly capped out-of-pocket costs at $35 per month for commercially insured patients at participating pharmacies and cut list prices on Humalog and Humulin by 70 percent.7Eli Lilly and Company. Lilly Cuts Insulin Prices by 70% and Caps Patient Insulin Out-of-Pocket Cost at $35 Sanofi announced a $35 commercial cap the same month, along with a 78 percent list price cut for Lantus and a 70 percent cut for Apidra effective January 1, 2024.8Sanofi. Sanofi Cuts U.S. List Price of Lantus, Its Most Prescribed Insulin Novo Nordisk made a similar $35 commitment.
These are voluntary programs with eligibility requirements and expiration dates. Patients enrolled in Medicare, Medicaid, or VA coverage are generally excluded from manufacturer savings cards, though those programs have their own protections.
If You Are Uninsured
Lilly’s Insulin Value Program and Sanofi’s Insulins Valyou Savings Program offer insulin at $35 per 30-day supply with no income requirements.8Sanofi. Sanofi Cuts U.S. List Price of Lantus, Its Most Prescribed Insulin Lilly also sells non-branded insulin lispro at $25 per vial.7Eli Lilly and Company. Lilly Cuts Insulin Prices by 70% and Caps Patient Insulin Out-of-Pocket Cost at $35
FQHCs are required to use sliding fee scales based on income. Patients at or below the federal poverty level pay only a nominal charge for services and medications.9Health Resources & Services Administration. Chapter 9 – Sliding Fee Discount Program This is the population the 2025 executive order is aimed at, and if the rule takes effect, uninsured patients getting insulin at an FQHC would pay the 340B acquisition cost plus a minimal fee — a price that in many cases is already low under the existing sliding fee framework.
The Remaining Gap
One group falls through every current protection: commercially insured patients whose employers self-fund their health plans, living in states without an insulin copay cap. Federal law doesn’t cap their costs (the Medicare cap doesn’t reach them), state law usually doesn’t reach ERISA plans, and manufacturer savings cards depend on the patient qualifying and the pharmacy participating. The executive order doesn’t reach them either, unless they happen to get insulin through an FQHC and meet one of the three eligibility categories.
Whether the 2025 rule finishes rulemaking, survives the same objections that stalled the 2020 version, and starts changing prices at community health centers is still open. What has already changed insulin costs for most Americans since 2020 was not this executive order but the Inflation Reduction Act, the wave of state copay laws, and the manufacturer price cuts announced in 2023.