
AMP is WAC (and other thoughts)
Latest posts and updates
You can subscribe to AMP is WAC at https://apteka.substack.com/

Latest posts and updates
You can subscribe to AMP is WAC at https://apteka.substack.com/
ABOUT AMP is WAC
Average Manufacturer Price (AMP) is not equal to Wholesale Acquisition Cost (WAC), but it is close. And since the whole world of health policy and reimbursement is a bit WAC-y, that’s what we’re calling this update/blog part of the site. All of the opinions and thoughts presented here are our own and not the views of clients or affiliates.
What the math. Yesterday afternoon CMS released a technical memo on the changes to True Out-of-Pocket (TrOOP) Costs and the maximum monthly cap for the Medicare prescription payment plan (MP3.) Simply put, they put out a memo that shows the math for the smoothing program. I need to work through some of the examples because,…
Updated 8/8/24. I live in a headspace that assumes everyone is up to date on the nuances of things and that I don’t need to write about it because it’s old news. And then I read this article in the Pink Sheet on how Medicare-negotiated prices may not get favorable coverage and realized that nope,…
Just… wow. Healthcare has a lot of rabbit holes but as the head of the Department of Health and Human Services, copay accumulators should be understood at a basic level. I’m not asking about alternative funding and to draw up a case study. Just that accumulators can’t be used in Medicare. Basics. Heck a simple…
Last week MedPAC, the Medicare advisory committee to Congress, had a really interesting session on generic drug pricing in the Medicare prescription drug program (Part D.) There is always so much focus on branded drugs that an opportunity to flip the script and learn about the 90% of prescription drug utilization in Part D (and…
PDAB-adieu. This week Governor Youngkin vetoed a bill that would have established a prescription drug affordability board (PDAB) in the state. The PDAB would have had authority over state-sponsored and state-regulated health plans. Younkin said that the PDAB would have determined drug availability solely on cost rather than unique patient needs and the opinions of…
Confession. I think Mark Cuban’s Cost Plus Drugs is underwhelming at best and, at worst, the death of independent pharmacies. I’ve been following it since inception, and I just can’t get excited about it – at least not yet. Cost Plus Drugs dispenses about 3,000 generic drugs. There is the transparent price, a 15% markup,…
Ruling It. Yesterday afternoon, the Centers for Medicare & Medicaid Services released the MA/Part D final rule. Personally, most of it was not up my alley but I did read over the changes to the changes to an approved formulary sections. In December 2022, CMS proposed allowing immediate substitution of interchangeable biosimilars or branded biologics…
Late Monday, the Centers for Medicare & Medicaid Services (CMS) released the Calendar Year (CY) 2025 Rate Announcement for Medicare Advantage and the Medicare Prescription Drug Program (Part D) as well as the CY25 Part D Redesign Program Instructions. I was about to get on an airplane and instead of watching a movie, I figured what sounds like a…
It has been a week of odds and ends so if you’re catching up after ignoring your emails, you didn’t miss a ton. Honestly, it seems like a good time to be a DC law firm working on pharmaceutical issues. You have the usual Inflation Reduction Act submissions, comment letters (which, for what it is…
I’m out and about this week so I’m reposting a piece I wrote last year…. If you missed it, I wrote about 340B basics. Here is a quick summary: There are hospitals, clinics, etc. that serve uninsured individuals. To help care for these patients, the 340B program requires pharmaceutical manufacturers (that wish to participate in…