Monthly GP Update: February 2025
Feb 5, 2025
By now, your Q4 and December 2024 calculations should be about wrapped up! If you are in the Government Pricing (GP) space, that means it’s about time to get started on your next monthly calculations.
Things that are due in the next 30 – 45 days include:
NFAMP (February 14),
TRICARE refunds/rebates (February 19),
PHS/340B pricing to HRSA (February 28) and to wholesalers/distributors (March 15),
Payments that are part of the Discarded Drug Refund program via MPP (February 28),
Monthly AMP submitted and certified in MDP (March 3), and
Payment for the Medicare Manufacturer Discount Program Part D rebates via MPP (March 11).
Remember, you can always find upcoming GP deadlines, conferences, and related activities on our online calendar.
In other GP news:
CMS announced the next round of drugs selected for Medicare Drug Price Negotiations and issued a Fact Sheet that provides more information for this round.
It seems none of the players involved with the PHS/340B program is happy while states, covered entities, and manufacturers continue to play what feels like a game of “cat and mouse.” The program has been the subject of more media attention, including The New York Times and we expect to see additional legislation proposed that, if passed, could more clearly define some of the issues we’ve seen from all stakeholders. Additionally, the courts are full of numerous PHS/340B cases, including:
At least eight states have enacted some sort of legislation regarding the program and there are outstanding legal challenges in seven states.
Manufacturers continue to challenge restrictions on “how” they offer the mandated discounts.
Covered entities have challenged manufacturer audits authorized by HRSA.
Sagebrush Health affiliates have appealed HRSA’s decision to strip them of their eligibility.
As with all of our blog posts and client alerts (which you can sign up for here), this information is intended to provide general guidance and to provide general industry information and/or context for potential activity in the near future. Some of it may not apply to your company and there may be other requirements that are not included here.
If you have any questions on these matters or about Government Pricing in general, feel free to reach out at any time.