Ms. Devlin added that after Mylan’s recent acquisition of Meda, a company specializing in women’s health, respiratory, allergy, dermatology and pain management, the EpiPen business will represent under 10 percent of the company’s revenue, compared with 11 percent last year.

But Brian Foley, an independent compensation consultant in White Plains, said it was impossible to separate the company’s business decisions from its pay practices. “The pattern of conduct with the EpiPen business seems egregious,” Mr. Foley said in an interview. “It looks like price gouging, and why would you do that? The answer has got to be because it’s in management’s financial interest to do it.”

Consider the special stock award. In 2014, Mylan’s proxy filings valued Ms. Bresch’s grant at $13.2 million. If Mylan clears the price and adjusted earnings hurdle, her payout will be far larger.

Now, though, with Mylan’s pricing practices under scrutiny, it may be more difficult for the company’s executives to clear the hurdles necessary to cash in. Its stock is well below the $53.33 price that will be needed to generate a payout. And the company’s decision last week to start selling a generic EpiPen at half the $600 branded price means the adjusted earnings per share target of $5.40 on Dec. 31, 2018 may be more difficult to achieve.

But don’t cry for Ms. Bresch. It turns out the earnings hurdle put in place by the board has some wiggle room. That’s because it is based not on generally accepted accounting principles but on a so-called adjusted earnings figure that excludes certain corporate costs chosen by Mylan. The company also uses fantasy figures when calculating its top executives’ incentive pay packages.

Among the costs Mylan excludes from its adjusted earnings are those related to acquisitions, financing and investment losses. Last year, these and other exclusions gave a big lift to Mylan’s pretend per-share earnings. Under generally accepted accounting principles, each Mylan share earned $1.70 in 2015. Under its own rules, each share earned $4.30.

That spread between Mylan’s actual earnings and its pretend number — $2.60 a share — has widened significantly. In 2014, it was $1.22 a share.