Monthly GP Update: October 2025

October is usually one of the busiest months in Government Pricing and this year is no exception. Beyond routine reporting, our attention is focused on significant regulatory pressures, including potential tariffs, Most-Favored-Nation (MFN) pricing initiatives, and continued complexities within the 340B program.

Depending on your products, here are some notable reminders and deadlines for this month:

1. Medicare Part D:

• 2Q2025 Part D payments are due on October 9, 2025.

• 2023 and 2024 Part D inflationary rebates, which were delayed until this year, have been released. Preliminary reports were published September 8, 2025 and they will be invoiced by December 31, 2025 with payment due 30 days after receipt, so on or around January 30, 2026.

2. Medicare Part B:

• 2023 and 2024 Part B Inflationary rebates, which were also delayed until this year, are due October 29, 2025. Invoices were published in MPP on September 29, 2025.

• 1Q2025 Part B Inflationary Rebates are due October 30, 2025.

3. VA/FFS:

• The Dear Manufacturer's Letter (DML) for Public Law will be distributed on or around October 15, 2025. (This is the annual process to establish FSS prices for the following calendar year.)

• Reporting of Q3 FSS Sales and the associated IFF Payment are due on October 30, 2025.

• NFAMP workbooks that will be sent out by the VA in the next few weeks must be reviewed and confirmation sent to the VA, most likely by October 31, 2025.

• eSRS reporting which is for manufacturers required to submit a subcontracting plan, is due October 31, 2025.

4. September Monthly AMP and all Q3 Quarterly Calcs (AMP, BP, URA, PHS/340B, NFAMP, ASP, CPPD’s, Nominal Sales) are all due October 30, 2025.

5. 2Q2025 Medicaid rebate invoicing is winding down and the bulk of invoices should have been received by now. 3Q2025 invoices will start to arrive around November 10, 2025, so now is a good time to clean up any stragglers or adjustments.

Tariffs have made their way into the conversation of pharmaceuticals. While official guidance has not been provided at this time, the President announced last week that branded/patented drugs will incur a 100% tariff which could take effect tomorrow (October 1, 2025). The exception to this would be for manufacturers who are building a manufacturing facility within the US, although information as to what would qualify for that has not been provided. We are keeping an eye out for further updates and if you want more information on this topic, Foley Hoag has a great article here.

In similar news, the White House sent out a letter to 17 drug manufacturers in July, outlining steps to reduce drug prices and implement MFN pricing. While there has been no guidance or legal requirements provided, if you’re curious on what those steps might include, check out this article by McDermott Will & Schulte. The list looks to target drug manufacturers directly; however, a downstream effect could be seen through the State Medicaid Programs and for participants of the 340B program, if enacted.

As a reminder, 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 a specific question. And as we regularly remind our clients, this information is not company specific but rather, is intended to provide general guidance. Our goals are to provide general information or context for current GP-related activities 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. If you have any questions or need assistance on these topics or any other GP-related issue, please let us know and we'd be happy to speak with you in greater detail.