Happy New Year!
Jan 9, 2025
A new year often brings new ideas, connections, and opportunities. At The Pricing Group, we’re excited about 2025 and the ever-changing world of Government Pricing.
In 2024, we saw a lot of activity, but what was most notable to many were the actions by both manufacturers and the states regarding the PHS/340B program. While states are enacting legislation to protect the use of Contract Pharmacies, manufacturers are attempting to put restrictions around their use and/or implement new requirements for purchases (e.g., rebate model). This will likely continue until Congress passes new legislation to clarify the requirements/permissible restrictions and/or the US Supreme Court takes one of these cases working its way through the appeals process.
In addition to the anticipated continuation of the PHS/340B activity, the level of effort and activity for manufacturers who participate in Medicare will likely increase in 2025. The new Manufacturer Payment Portal went live last month with the Discarded Drug Program module.
The CGDP should be available this month; the Manufacturer Discount Program is expected to be available in April; and the Inflation Rebates module will be available in July. The most recent User Guide was released last month, and at 147 pages, it’s helpful while also being very thorough. Also regarding Medicare, manufacturers should ensure they are accruing for any Inflation Rebates that will be received in 2025. (Remember when that felt like it was so far out?) Rebates for Part B are likely to be received in September and for Part D, in December.
Here are some key upcoming GP-related dates/deadlines that should be on your radar, depending on your company’s products during Q1 2025:
New Mexico AMP-related reporting is due January 15
Manufacturers are expected to enter their applicable contact information for the Medicare Inflation Rebate program by January 15.
December and Q4 Calcs (AMP, BP, URA, ASP, CPPDs, Nominal Sale, IFF, and IFF payment) are due January 30
NFAMP is due February 14
PHS/340B pricing is due to HRSA February 28 and to wholesalers/distributors by March 15
Payment for the Medicare Manufacturer Discount Program Part D rebates is due March 11
(You can always find upcoming GP deadlines, conferences, and related activities on our calendar.)
Feel free to reach out at any time if you have any general GP questions or would like to discuss our services and capabilities. We are always happy to chat about GP or just about your plans and expectations for the new year.
And on behalf of the entire team at The Pricing Group, we hope your 2025 is filled with peace, laughter, joy and of course, new opportunities.
Interested in more GP updates like this? We send a more in-depth version to our clients every month. Reach out to learn more about our services!