Monthly GP Update: November 2025
Nov 4, 2025
If you’re like us at The Pricing Group, October has proven to be as busy as we expected. Here are a few other upcoming GP deadlines and activities of note:
Public Law for the VA/FSS Contract is in full swing. The CPI-U to be used is 3.01%. (Note, NFAMP annual workbooks were populated with 0.00% and will be adjusted when the PBM calculates pricing.) Here are a few remaining items:
October 30: If applicable, your VA eSRS data is due.
October 31: Report modifications to your NFAMP methodology to the PBM, OGC, and OIG, if applicable.
Report any disputes of the FSS pricing on September 30, 2025 or the old NFAMP entries.
November 15: Submit the annual and new, or Q3 2025, NFAMP results to the PBM.
December 1: Submit the PPA Addendum for 2026 FCPs and the RFM (ensure the Subject Line on your email includes “RFM-Contract Number-PL2026”)
And for all other GP tasks, below is a summary of those that are due within the next 30 days:
October 29: 2023/2024 Part B Inflationary Rebates were due via HPMS
October 30: September AMP
Q3 AMP, BP, CPPDs, Nominal Sales
Q3 Medicaid-Related State Reporting
Q3 ASP
Q3 FSS Sales and IFF Payment
Q1 2025 Part B Inflationary Rebates via HPMS
November 20: TRICARE Payment to the VA
November 28: PHS/340B Prices via OPAIS (Q3 2025 calculations to set Q1 2026 prices)
(Remember, you can always find upcoming GP deadlines, conferences, and related activities at The Pricing Group’s online calendar or reach out to us if you have any questions.)
With the government shutdown, nothing new has been enacted but despite the shutdown, the Senate has continued to hold hearings on the PHS/340B Program. Many of the Senators agree there is a need for reform but there is not a consensus on how to accomplish this or what that would look like.
Speaking of the government shutdown, one of the big “sticking points” is around the subsidies received by many individuals who get their healthcare coverage through the Exchange, aka, Obamacare. The expanded subsidies that were introduced as part of the American Rescue Plan Act of 2021, and subsequently extended via the Inflation Reduction Act, are set to expire at the end of 2025. Many analysts believe that if these enhanced subsidies are eliminated (or significantly reduced), a large number of marketplace enrollees will face much higher premiums and may find coverage unaffordable. The downstream impact of this will be a greater number of uninsured patients which could lead to increased strain on safety-net providers and thereby greater reliance on the PHS/340B program. Depending on your product(s), you may want to revisit your accruals if this occurs.
Just a reminder that even in October, the team at The Pricing Group loves Government Pricing so if you have any questions or would like to discuss any new products or strategies, let us know. It’s what we do!
P.S. 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. When in doubt, please reach out to us and/or your legal counsel.