The “Changes to Medicaid Payment for Prescription Drugs” (page 55) sets the Federal Upper Limit (FUL) to the weighted Average Manufacturer Price (WAMP?) x 175%, i.e., WAMP+75%.
Quick reaction: While 175% is less than 250%, I expect WAMP to be greater than AMP, especially since the proposal excludes mail order pharmacies. Seems like a victory for the pharmacy groups that lobbied for an increase, although I predict they will still ask for more.
Here’s the full text of the proposal:
“The Chairman‘s Mark would change the FUL to 175 percent of the weighted average (determined on the basis of utilization) of the most recent AMPs for pharmaceutically and therapeutically equivalent multiple source drugs available nationally through commercial pharmacies. The Mark also would clarify what transactions, discounts, and other price adjustments were included in the definition of AMP. Additionally, the Mark would clarify that retail survey prices do not include mail order and long term care pharmacies. The Mark also would expand the disclosure requirement to include monthly weighted average AMPs and retail survey prices.”Note the last sentence means that AMP (and its variants) will be disclosed. We are one step closer to a new model for pharmacy reimbursement in the post-AWP world.