When Can Biosimilars Be Automatically Substituted? U.S. Rules Explained

When Can Biosimilars Be Automatically Substituted? U.S. Rules Explained
18 Jan, 2026
by Trevor Ockley | Jan, 18 2026 | Health | 10 Comments

When you pick up a prescription for insulin or a biologic drug like Humira, you might not realize the pill you’re handed could be a completely different product than what your doctor ordered-and that’s by design. In the U.S., certain biosimilars can be swapped in at the pharmacy without your doctor’s approval. This isn’t like switching from brand-name aspirin to generic ibuprofen. It’s more complex, more regulated, and far more controversial. The key term here is interchangeable biosimilar.

What Makes a Biosimilar ‘Interchangeable’?

Not all biosimilars are created equal. The FDA approves two types: biosimilars and interchangeable biosimilars. Both are highly similar to the original biologic drug-like Humira, Enbrel, or Lantus-but only one type can be swapped automatically at the pharmacy counter.

A biosimilar must prove it works the same way as the reference product in terms of safety, purity, and potency. That’s tough. Biologics are made from living cells, not chemicals. Even tiny changes in manufacturing can affect how they behave in your body. So the FDA requires extensive testing, including clinical trials.

But to be labeled interchangeable, a biosimilar must go further. It must show that switching back and forth between the reference drug and the biosimilar-multiple times-doesn’t increase risk or reduce effectiveness. That’s not just a one-time comparison. It’s a series of switches, often in the same patient group, with careful monitoring of immune responses, side effects, and how the drug moves through the body.

The first interchangeable biosimilar approved was Semglee, an insulin glargine product, in July 2021. The first interchangeable monoclonal antibody-Cyltezo, a Humira alternative-came in August 2023. As of November 2023, only 10 out of 41 approved biosimilars had this special designation.

Why Does This Even Matter?

Biologics are expensive. Humira alone cost over $70,000 per year before biosimilars entered the market. Even non-interchangeable biosimilars are 15-30% cheaper, according to a 2022 RAND Corporation study. But automatic substitution drives adoption faster.

When a pharmacist can swap a brand-name drug for a biosimilar without calling the doctor, more patients get the cheaper version. In states with automatic substitution laws, insulin biosimilar use jumped 18.7% compared to states that don’t allow it, according to a 2023 JAMA Health Forum study. That’s not just savings-it’s access.

For patients, it means lower out-of-pocket costs. One person on the Psoriasis Foundation forum reported saving $800 a month after switching from Humira to Hyrimoz, an interchangeable biosimilar. For insurers and employers, it means lower drug spending. Commercial plans now often require automatic substitution for interchangeable biosimilars when state law allows it.

How Is This Different From Generic Drugs?

Think of generic drugs as exact copies. A generic pill has the same active ingredient, dose, and chemical structure as the brand. The FDA can approve them based on bioequivalence studies-showing the body absorbs them the same way.

Biosimilars aren’t copies. They’re highly similar, but not identical. Because they’re made from living cells, no two batches are exactly alike-even from the same manufacturer. That’s why the FDA requires way more data for biosimilars than for generics. And for interchangeability? Even more.

It’s not just about whether the drug works. It’s about whether switching between products over time is safe. That’s why a generic for metformin can be swapped without any extra testing. But a biosimilar for Enbrel? Not unless it’s been proven safe through multiple switches.

U.S. map showing state-by-state biosimilar substitution laws with geometric icons

State Laws Are a Mess

The FDA says a biosimilar is interchangeable. But whether a pharmacist can actually swap it? That’s up to your state.

Forty states and Washington, D.C., allow pharmacists to substitute an interchangeable biosimilar without telling the doctor. Some, like Arizona, require the pharmacist to notify the patient and send a record to the prescriber within five days. Others, like California, only allow substitution if it saves the patient money.

Then there are the holdouts. Alabama, Indiana, South Carolina, and Washington require the prescriber’s explicit approval before any substitution-even if the biosimilar is FDA-interchangeable. Puerto Rico has the same rule.

This patchwork creates real headaches. A 2022 survey by the National Community Pharmacists Association found that 67% of independent pharmacists were confused about what they could and couldn’t do depending on the state. One pharmacist on Reddit wrote: “In California, I have to check if it’s lower cost. In Arizona, I don’t. My pharmacy system doesn’t differentiate between states.”

What About Patient Safety?

Critics worry that automatic substitution could hurt patients. In a 2021 JAMA Dermatology editorial, Dr. Kevin Winthrop pointed to a study showing psoriasis patients switched to biosimilars had a 20.3% higher chance of stopping treatment than those who stayed on the original drug. Reasons? Uncertainty, fear, or real side effects.

One patient reported an allergic reaction after their pharmacy switched them from Humira to Hadlima without telling them. Turns out, they were sensitive to an excipient-the inactive ingredient-in the biosimilar. The FDA says all approved biosimilars are as safe as the reference product. But patients aren’t always told when a switch happens.

A 2022 National Psoriasis Foundation survey found 63% of patients were satisfied with their biosimilar, but 28% were upset they weren’t informed. Transparency matters. Patients need to know what they’re getting, especially when switching between products.

Patient holding two insulin pens with immune system reactions and state symbols

What’s Next for Biosimilars?

The market is growing fast. By 2026, biosimilars could capture nearly half of the $168 billion biologics market, according to Evaluate Pharma. But the path forward is tangled.

There’s a bill in Congress called the Biosimilar Red Tape Elimination Act. It would scrap the requirement for switching studies and make every FDA-approved biosimilar automatically interchangeable. Supporters say it’s the fastest way to drive down prices. Critics-including big pharma-say it risks patient safety by skipping critical data.

The FDA is also reviewing its guidance. In 2023, it proposed streamlining the switching study requirements, which could speed up approvals. Meanwhile, more biologics are losing patent protection. By 2025, 70% of the top 20 biologic drugs by sales will face biosimilar competition.

The insulin market already shows the power of interchangeability. Semglee hit 17.3% market share within six months-nearly double the pace of non-interchangeable biosimilars.

What Should You Do?

If you’re on a biologic drug:

  • Ask your doctor: Is there an interchangeable biosimilar available?
  • Ask your pharmacist: Will they substitute it automatically? Do they need your permission?
  • Check your state’s laws. They vary-and you have rights.
  • Make sure you’re notified if a switch happens. You have the right to know what you’re taking.
  • If you feel worse after a switch, tell your doctor immediately. It’s not always the drug-it could be an excipient.
Pharmacists are being trained. The American Pharmacists Association has certified over 12,000 pharmacists in biosimilars as of late 2023. But the system is still learning. Knowledge gaps are real. So don’t assume anything. Ask questions.

Frequently Asked Questions

Can any biosimilar be automatically substituted at the pharmacy?

No. Only biosimilars that have received the FDA’s ‘interchangeable’ designation can be substituted without a doctor’s approval. As of late 2023, only 10 out of 41 approved biosimilars have this status. All other biosimilars require the prescriber to specifically allow substitution.

Are interchangeable biosimilars safer or more effective than regular biosimilars?

No. The FDA says all approved biosimilars-interchangeable or not-are equally safe and effective as the original biologic. The ‘interchangeable’ label only means the product has passed additional testing to prove it’s safe to switch back and forth with the reference drug. It doesn’t mean it’s better.

Can a pharmacist substitute one biosimilar for another?

No. Interchangeability only applies to swapping a biosimilar for the original reference product, not for switching between two different biosimilars. For example, if you’re on Cyltezo (a Humira biosimilar), your pharmacist can’t swap you to Hyrimoz without your doctor’s approval-even if both are interchangeable with Humira.

Do I have to be told if my prescription is switched to a biosimilar?

It depends on your state. In some states like Arizona, pharmacists must notify you and send a record to your doctor. In others, there’s no legal requirement to inform you. Always ask your pharmacist what’s being dispensed. You have the right to know.

Can my doctor stop a biosimilar substitution?

Yes. Every state allows prescribers to prevent substitution by writing ‘dispense as written’ or using a specific DAW code on the prescription. Even in states with automatic substitution laws, your doctor’s instruction overrides pharmacy rules.

10 Comments

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    Jacob Cathro

    January 18, 2026 AT 15:34
    So let me get this straight-pharmacists can swap my $70k/year Humira for some biosimilar I’ve never heard of, and I might not even know until I get the receipt? 🤡 This is why I don’t trust the system. They don’t care if I break out in hives or start crying for no reason. Just slap on the label and call it ‘interchangeable’ like it’s a damn coupon.

    Also, who the hell approved this? FDA? More like FDA: Fast Drug Approval™. I’m not a lab rat.
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    Paul Barnes

    January 18, 2026 AT 20:33
    The distinction between biosimilars and interchangeable biosimilars is legally and scientifically well-defined by the FDA under the Biologics Price Competition and Innovation Act of 2009. The requirement for multiple-switch studies is not arbitrary; it is based on pharmacokinetic and immunogenicity data demonstrating clinical equivalence under dynamic switching conditions. To conflate this with generic drug approval is a fundamental misunderstanding of biologics manufacturing complexity.
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    pragya mishra

    January 19, 2026 AT 20:20
    Why are Americans so scared of saving money? In India, we’ve been using biosimilars for over a decade-cheaper, same results. My uncle has rheumatoid arthritis and switched from Enbrel to a biosimilar. He saves $500/month. No one died. No one cried. He just paid less. Stop making this a drama. Your fear is costing lives.
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    Andy Thompson

    January 21, 2026 AT 06:34
    They’re lying to us. This is Big Pharma’s plan to kill off American healthcare. The FDA is in bed with the drug companies. Why do you think only 10 out of 41 are interchangeable? Because they don’t want you to know how easy it is to fake these studies. I saw a video on TruthFeed-some guy in a lab coat swapped vials and nobody noticed. 🤫

    Also, if your pharmacist swaps your insulin, call the police. Or better yet, move to Canada. They don’t do this shit there. #BiosimilarScam
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    sagar sanadi

    January 22, 2026 AT 17:03
    Interchangeable? More like interchangeable with your health. They just want to sell you the cheap version and call it a day. You think your body can’t tell the difference? Your immune system isn’t dumb. It remembers. And when it gets mad? You’re the one paying the bill in ER visits. Meanwhile, the CEOs are sipping champagne in Switzerland. 😎
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    kumar kc

    January 24, 2026 AT 13:38
    Patients have a right to know what they’re injected with. Period. No excuses.
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    Shane McGriff

    January 25, 2026 AT 20:21
    I’ve been on Humira for 8 years. My doctor switched me to Cyltezo last year-interchangeable, FDA-approved, and my insurance covered it 95%. I didn’t feel any different. No rashes, no flares, no weird side effects. I saved $600/month. I get why people are scared-change is scary. But this isn’t a gamble. It’s science. Talk to your doctor. Ask questions. But don’t let fear stop you from saving your wallet-and maybe your life.
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    Art Gar

    January 26, 2026 AT 22:53
    The regulatory framework governing biosimilar interchangeability is predicated upon rigorous analytical, nonclinical, and clinical comparability assessments. The FDA’s guidance documents, particularly those issued in 2015 and updated in 2023, explicitly delineate the evidentiary thresholds required for interchangeability designation. To assert that the current process is insufficiently robust is to misrepresent the evidentiary burden imposed upon manufacturers.
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    Crystal August

    January 28, 2026 AT 11:37
    I don’t care how many studies they run. If I’m not told I’m getting a different drug, that’s a violation. I don’t care if it’s ‘the same.’ I didn’t consent. This isn’t about cost-it’s about autonomy. And if my pharmacist doesn’t ask me, I’m taking my business to a clinic that treats me like a person, not a number.
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    Nadia Watson

    January 30, 2026 AT 09:26
    I work in a pharmacy in Texas, and honestly? We’re all just trying to keep up. Some states say notify the patient. Some say only if it’s cheaper. Some say nothing. Our system doesn’t even flag the difference between states. Last week I swapped someone’s insulin and didn’t realize until they came back mad because they thought it was the same brand. I apologized. I learned. But we need better tools. And patients? They deserve clarity, not confusion. Please ask. Always ask. We’re trying.

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