Meet
Emily Donaldson

Principal

Emily Donaldson provides strategic advice and policy analysis to a wide range of clients across the healthcare industry.

Before joining Avalere, Emily served as director of US Policy at AbbVie, where she developed policies and strategies to help the business navigate the private health insurance and Medicaid markets, the 340B program, and the state health policy landscape. Previously, she served as deputy vice president for the Policy and Research department at PhRMA, where she led the commercial market and state issues portfolios. She has also served as director of state policy at the Blue Cross Blue Shield Association, policy counsel for BlueCross BlueShield of South Carolina, and staff counsel for the South Carolina Senate’s Office of Senate Research.

Emily holds a JD from the University of South Carolina and a BFA from Columbia College.

Authored Content


HRSA’s new 340B rebate pilot for negotiated drugs in 2026 introduces reporting and payment rules, introducing both transparency and new risks for stakeholders.

State oversight of AI in healthcare has primarily focused on prior authorization, disclosure and operations requirements, and scope of practice.

A new EO revives international reference pricing as a core Trump administration priority, with a focus on Most-Favored Nation pricing through direct-to-consumer models, regulatory action, and broader enforcement measures.

New Executive Order on drug pricing revives earlier Trump proposals and also suggests new approaches for Medicare and states.

Legislation aimed at changing how PBMs operate, including “delinking” bills, could have unforeseen consequences for drug prices, contracting and competition.

From 2016 to 2024, buyer hospitals undergoing mergers or acquisitions were more likely to be large (500+ beds) and 340B covered entities.

In interviews and a survey, health plans communicate concerns with UPLs’ potential impact on patient access, pharmacists, providers, and their own financial positions.

With less than a year until the first MFPs take effect, stakeholder concerns remain, especially as it relates to 340B duplicate discount risk.

The 340B program may create unintended consequences for state Medicaid budgets and patients who may not see direct benefits from the program.

HRSA 2023 340B purchase data demonstrates continued program growth and that sales for the top 10 340B drugs exceeded sales for those drugs in Medicare.

In preparation for the 2024 state legislative sessions, stakeholders should consider how states will continue to shape the 340B policy landscape.

Some federal grant recipients use 340B program eligibility to expand their reach and services provided to a wide range of patient populations.

Key 340B stakeholders include the federal government, patients, pharmacies, drug manufacturers, PBMs, plans, and the 340B prime vendor.

Section 340B of the Public Health Service Act requires significant discounts on outpatient drugs for “covered entities"—safety-net providers and programs.

The SCOTUS decision is the most prominent action related to the 340B program, but ongoing litigation among stakeholders and growing activity at the state level are catalyzing developments that could shape the 340B landscape

Avalere analysis finds that Congress's healthcare reforms under the COVID-19 relief bill could expand exchange coverage subsidies for up to 18.3 million individuals.