Monthly GP Update: March 2025
Mar 4, 2025
The more things change, the more they stay the same. Even though it’s the beginning of a new year, there’s a new administration in the White House, and there’s still a lot going on in Government Pricing.
This month, depending on your products, here is what is going on in GP:
Payment for the Medicare Manufacturer Discount Program Part D rebates via MPP is due March 11. The penalty for late payment is 25 percent of the rebate amount so make sure you get this payment submitted on time.
PHS/340B pricing is due to your wholesalers/distributors by March 15.
Since March 30 falls on a Sunday, February monthly AMP is due March 31.
The Medicaid invoices for Q4 2024 should have started to arrive a couple of weeks ago and you should have received the bulk of them by now.
We will be speaking at a couple of different events in the next few months. Both are great opportunities for your team to brush up on their skills or learn something new:
Life Sciences Accounting and Reporting Conference on March 18-20 in Philadelphia
Pricing and Contracting USA on May 19-21, also in Philadelphia
Remember, our online calendar is a great resource for conferences and things like GP-related deadlines!
Yesterday, a notice was published in the Federal Register (Vol. 90, No. 40) that, effective immediately, Secretary Robert F. Kennedy, Jr of the Department of Health and Human Services (HHS) has rescinded a policy that included public participation in rule making, referred to as, “The Richardson Waiver.” Historically, an agency issues a Proposed Rule that outlines potential changes to regulations and allows time for public comment. The agency then reviews the comments, potentially issues a revised Proposed Rule, and eventually issues a Final Rule. Often, the public comments help identify issues in the original Proposed Rule so the Final Rule is stronger and/or clearer. Both Medicaid and Medicare are subject to the “notice and comment” requirements for substantive policy changes so this may not have any impact on the substance of the programs but that remains to be seen – keep checking back with The Price Point for updates.
We could write pages on the happenings in the PHS/340B program but will simply say that the “cat and mouse” game we mentioned last month continues with states enacting legislation, challenges to such legislation, new restrictions introduced by manufacturers to restrict the mechanism of the required discount, and actions by the covered entities to maximize their revenue from this program. If there’s something specific you would like to know more about, just let us know.
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're interested in updates like these, we send out a more in-depth version to our clients every month. Please reach out for more information.