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Spotlight

This page provides a brief summary on the latest information and/or updates on Medicaid pharmacy policy and reimbursement as well as policy on manufacturer reporting.  New item will be listed at the top with the subject title capitalized.  Please check back often for timely announcements, corrections, and updates.

STATE MEDICAID PRESCRIPTION REIMBURSEMENT INFORMATION BY STATE - Quarter ending September 2009 has been updated.  Please click on the State Medicaid Prescription Reimbursement Information link on the left to view the latest update.

Clarification On Postmark Date For Web Invoices - Recently, we have received questions from States that have decided to use a secured web site as the method of providing manufacturers their quarterly rebate invoices as to what constitutes a postmark date. Under section II(b) of the Medicaid Drug Rebate Agreement, it is stated that "the Manufacturer is responsible for timely payment of the rebate within 30 days of receiving, at minimum, information on the number of units paid, by NDC." Therefore, we expect that when using electronic invoicing via email, States include the invoice itself within the body of the email to a manufacturer or, at minimum, information on the number of units paid by NDC. In this case, we view the postmark date as the date on which the email is sent. Please note that the date an email is sent with a link to an invoice web site does not qualify as a postmark date. If States choose to direct manufacturers to an invoice web site via a link in the email, then States need to include the invoice itself within the body of the email to a manufacturer or, at minimum, information on the number of units paid by NDC.

Treatment Of TriCare Retail Pharmacy Benefit Plan Transactions - Recently, CMS issued guidance on the treatment of prices to DoD in the determination of AMP and BP in State Release #152.  To access the State releases, please click on the State Releases link under Related Link Inside CMS.

Guidance On Average Manufacturer Price (AMP) And Best Price (BP) Methodology Recalculations- A manufacturer that needs to make future recalculations regarding AMP and/or BP methodology may do so without prior review and approval by CMS.  However, we continue to request that manufacturers notify us of the change in the method used to calculate their AMP and/or BP, along with revised AMP and/or BP data to support the change for the drugs affected, the relevant 11-digit NDC numbers, the fiscal magnitude of the change, and a statement as to the reason for the change in methodology.  Manufacturers must report to CMS these revisions to AMP and/or BP for a period not to exceed 12 quarters from the quarter in which the data were due.  For more detail on this guidance, please view the download below.

Clarification on State Pharmaceutical Assistance Program (SPAP) Best Price List - It has come to our attention that manufacturers are relying upon the Medicare SPAP List (Qualified State Pharmaceuticals Assistance Programs Under the MMA) to determine whether a SPAP can be excluded from the Medicaid Best Price. The Medicaid SPAP Best Price list and Medicare SPAP list are two separate and distinct lists.  For the purposes of determining whether a SPAP is excluded from the Medicaid Best Price, manufacturers should refer to the Medicaid SPAP Best Price, which can be found by clicking on the SPAP Best Price link on the left.

Reporting Zero or Negative AMP - If a calculated monthly AMP is zero or negative, we recommend that manufacturers report the most recent prior month's positive AMP.  Please do not enter the value 99999.999999 or 0.000001 when you attempt to enter a value of zero for AMP.  However, please note the actual calculated monthly AMP should be used to calculate the quarterly AMP.  If the quarterly AMP is zero or negative, we recommend that manufacturers report the most recent positive AMP value. 

Disclaimer: Please note that links posted on the Spotlight web page alert the reader to certain updates and changes on policy pertaining, but not limited, to the Medicaid prescription drug program. These links will be updated on a regular basis and old ones will be removed. Please note that the Spotlight web page alerts readers to a limited number of CMS documents, and those documents do not constitute the entire body of Medicaid drug rebate statutory, regulatory, and other guidance.  Individuals must consider the information linked to on the Spotlight web page in conjunction with other relevant authority.

Downloads
Guidance on Average Manufacturer Price (AMP) and Best Price (BP) Methodology Recalculations [PDF, 23KB]
Related Links Inside CMS
Drug Manufacturer Releases

State Releases
Related Links Outside CMSExternal Linking Policy

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Page Last Modified: 10/26/2009 4:58:30 PM
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