AMP is WAC (and other thoughts)
Latest posts and updates
Latest posts and updates
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.
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…
If you’re one of those people who is working from the couch today, I salute you. It really is the most fun day of sports. I was mocked for the way I picked my bracket (where wouId I rather live?) but I had a clean bracket until Kentucky. I blame my newfound like of bourbon.…
One of the policies I’m stalking emails from the Centers for Medicare & Medicaid Services (CMS) is the final “Misclassification of Drugs, Program Administration and Program Integrity Updates Under the Medicaid Drug Rebate Program” rule. The draft came out last May and included a policy on the stacking of Best Price, but the final is…
It was one of those rare weeks in Washington, DC where the weather was just perfect. I mean not if you suffer from allergies, but for everyone else. Same Same. Last week we had the State of the Union, this week we had the President’s Budget release. For what it is worth, the budget is…
Last week I did an explainer on what pharmacy benefit managers (PBMs) are and where the pain points were and why there was a focus on PBM reform. There is a lot of buzz around PBM bills on Capitol Hill last year with lots of bills in motion but, for now, I’d thought I’d hone…
Happy International Women’s Day. Best display of International Women’s day I’ve ever seen was in Russia when I was studying abroad. They took it SERIOUSLY. Not just a LinkedIn Holiday. Cat-astrophe? No, just a political speech – not reality. President Biden talked about increasing the number of negotiated drugs up to 50 a year. Not…
There is a lot of talk about pharmacy benefit manager (PBM) reform. How PBMs aren’t transparent with pricing and can charge patients more at the point of sale than the drug costs the PBM. But I realized today that perhaps some background on PBMs and how we found ourselves here could be helpful for some…