The Pricing Group – Monthly GP Update: September 2026

Monthly GP Update: September 2026

Fall is in the air! With September underway and fall quickly approaching, your July calculations should have been submitted by August 31, and your Q2 Medicaid rebate invoices should be flowing in.

Upcoming Government Pricing Deadlines

  • September 15 - Q4 2026 PHS/340B pricing, derived from your Q2 2026 calculations, should be submitted to wholesalers and distributors

  • September 30 - August AMP submission due

  • October 15 - The annual Public Law season, which establishes calendar year 2027 VA/FSS pricing, will begin soon. You can expect to receive your workbook from the VA around this date, so you may want to begin preparing —especially since October tends to be one of the busiest months for Government Pricing.

Visit The Pricing Group’s online calendar for upcoming GP-related events and deadlines!

Educational and Networking Opportunities

If you’re interested in learning more about Government Pricing, consider attending IIR’s Medicaid Drug Rebate Program Summit, taking place October 5–7. Use discount code 26PRICINGGRP10 to receive 10% off your registration fee.

Our own Lisa Clayton will be speaking at the event on Building Your Government Pricing Foundation. The Pricing Group is also once again sponsoring the popular Relaxation Zone in the exhibit hall. Stop by to see us and enjoy a complimentary chair or hand massage!

If your schedule doesn’t allow for three days in Chicago, consider ACI’s Rx Drug Pricing and Rebate Fundamentals, a virtual program beginning November 2 and presented over four weeks.

Government Pricing “Hot Topics”

The PHS/340B program continues to grow in size, complexity, and controversy. It is unlikely that we will see significant changes to the program before the midterm elections, so we expect the ongoing game of “cat and mouse” to continue.

The 2027 Physician Fee Schedule Proposed Rule was published on July 16 and would require 340B covered entities to submit Medicare Part D claims data quarterly beginning in 2027. This is important for manufacturers because the data should help identify potential duplicate discounts associated with the two programs. As a reminder, comments are due September 14.

When the Auditor Asks, “How Did You Get There?”

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