Average Manufacturer Price
FDB now publishes the Average Manufacturer Price, thereby enabling the implementation of revised Federal Upper Limit (FUL) prices which will be updated on a monthly basis. Under the new methodology, these Affordable Care Act FULs will be calculated at “no less than 175% of the weighted average (determined on the basis of utilization) of the most recently reported monthly average manufacturer prices (AMP) for pharmaceutically and therapeutically equivalent multiple source drug products that are available for purchase by retail community pharmacies on a nationwide basis”.
The Final Rule
The Final Rule creates an exception to this methodology; when 175% of the weighted average AMP is “lower than the average retail community pharmacies’ acquisition cost for such drug product”, as determined by the most current national survey of such costs (NADAC), CMS will use a percent of the weighted average of the most recently reported monthly AMPs that equals the most current average acquisition costs paid by retail community pharmacies as determined by such survey.
Stated more simply, when the calculated FUL for a product is less than the NADAC, the NADAC will become the FUL. The Weighted Average of Average Manufacturer price (WAMP) is used by CMS to determine the Federal Upper Limit Price for an NDC. FDB will provide this price type from an NDC based external source file published by CMS. Note: Not all NDCs on FDB’s database will be associated with a federal price type (WAAMP, FUL, NADACG, NADACB).