Monthly GP Update: May 2026

With May now upon us, has your organization completed the VA Mass Modification (65 I B Mass Mod 0016)? This extends VA contracts up to 20 years, doubling the previous maximum performance period. Additionally, Q1 2026 calculations (AMP, BP, CPPDs, Nominal Sales, ASP, FSS Sales and IFF payment) should have been submitted and certified.

If you haven’t finalized these actions, please reach out to our team, we are happy to help!

New Section 232 Pharmaceutical Tariffs: What You Need To Know

President Trump has announced new Section 232 national security tariffs on imported pharmaceutical products. Affected companies are those that import a patented drug or it’s ingredients which includes manufacturers, importers, distributors, supply chain intermediaries, and companies importing APIs for domestic production. Noting that the tariff is assessed at the time of the importation, not based on who owns the drug (if an input to the drug is imported, it’s subject to the tariff - just the imported portion is subject to the tariff, not the entire finished product unless the finished product is imported). This new tariff is enforceable but could still face legal challenges as tariffs on other products have been largely unsuccessful.

Key Takeways:

• Target: Patented drugs and APIs (ingredients).

• Effective Dates: July 31, 2026 (17 companies - see Annexes II and III, pages 8-9); Sept 29, 2026 (all others).

• Exceptions: Currently exclude orphan drugs, generics, and biosimilars, though this may change next year.

• Action: This is a significant shift in trade policy that warrants review and consult from legal counsel to determine the impact to your organization, specifically when calculating accruals and determining your revenue.

Upcoming GP Deadlines: Mark Your Calendars

• May 14: Q1 2026 Quarterly NFAMP is due.

• Early to Mid-May: Q1 2026 Medicaid rebate invoices begin arriving.

• June 1: April AMP calculations are due.

• June 1: Q1 PHS/340B (setting Q3 pricing) calculations due to HRSA.

• June 15: Q1 PHS/340B calculations due to wholesalers/distributors.

Upcoming GP Networking Opportunities: Save The Date

• May 18-20: Life Sciences Pricing & Contracting USA (Philly) – Use code 26PRCGRP10 for 10% VIP discount. Don’t miss our very own, Lisa Clayton’s “Regulatory Whiplash” session!

• June 24-25: Big Four Pharma Pricing Boot Camp (Virtual).

• July 13-15: 340B Coalition Summer Conference (National Harbor, MD)

Looking Forward

• Stay Proactive: Upcoming GP deadlines, conferences, and related activities can always be found on The Pricing Group’s online calendar.

• General Guidance: Please remember, this information is intended to provide general industry context and is not company-specific. Some items may not apply to your organization, and other requirements may exist.

• Get in Touch: Have questions or want to dive deeper into these details? Contact us for a more tailored discussion.