Monthly GP Update: January 2026

Happy New Year!

A new year often brings new ideas, connections, and opportunities. As you may have seen from our recent announcement, Lisa Clayton has stepped into the role of Executive Director, and Katie Lapins has transitioned to Senior Advisor. Both changes will enable The Pricing Group to build on our past successes and continue to embrace the challenges that are likely to come in 2026.

Things continue to stay interesting in the world of the PHS/340B Program. While many of us were out of the office, the 340B Rebate Pilot Program was put on hold by a federal judge in Maine, finding that it likely violates the Administrative Procedure Act because Health Resources and Services Administration (HRSA) did not adequately prepare for the program nor did they account for the potential impact on 340B facilities. The judge further stated, “Defendants [The Federal Government] cannot fly the plane before they build it.” The Department of Health & Human Services (HHS) quickly appealed the order but the courts denied the request and for now, the Pilot Program continues to be on hold. A hearing on a preliminary injunction will likely be scheduled in January or February of 2026.

In January, depending on your company’s products, below are the upcoming GP-related items that should be on your radar:

1. Medicare Part D Inflation Rebates are due January 9.

2. New Mexico reporting of Q3 2024 AMP is due January 15.

3. December and Q4 Quarterly Calcs for 2024 are due January 30 (AMP, BP, URA, ASP, CPPDs, Nominal Sales) and NFAMP is due February 14.

4. Medicare Part B Inflation Rebates are due January 30.

5. The bulk of your Q3 Medicaid rebate invoices should have been received by now and Q4 invoices will start arriving early to mid-February.

And remember, you can always find upcoming GP deadlines, conferences, and related activities on our online calendar.

At the core of everything we do is a deep commitment to serving our clients. We recognize that being entrusted as your advisor is both a privilege and a responsibility that we approach with great care. If you have any questions or would like to discuss any new products, strategies, or have any general GP questions, feel free to reach out at any time. We wish you a bright and successful start to 2026, filled with joy, peace, and exciting opportunities.

Please remember, this information is not company specific but rather, is intended to provide general guidance. Our goals are to provide industry information or context for what may be occurring in the upcoming weeks and to help our clients be more proactive. Some of it may not apply to your organization and there may be other requirements that are not included here.