The Centers for Medicare & Medicaid Services (CMS) announced that it will publish the final average manufacturer price (AMP)-based federal upper limits (FULs) in late March 2016. The final AMP-based FULs will be effective on April 1, 2016, to correspond with the effective date of the final rule.

Once the rule is published, states will have up to 30 days from the April 1, 2016, to implement the FULs. However, states will have until April 2017, to move to cost-based product reimbursement and adjust dispensing fees. 

NACDS continues to work with in-state partners to assess state activities on implementation of the upcoming finalized AMP-based FULs, adoption of the cost-based reimbursement provisions of the Final Rule, and the transition to fair and accurate dispensing fees. Implementation of the final AMP-based FULs will significantly change pharmacy reimbursement for both brand and generic drugs dispensed to the Medicaid population.

In collaboration with in-state partners, NACDS is assessing how states have implemented acquisition cost-based reimbursement. Conducting cost of dispensing studies, when possible, and clear lines of communication with pharmacy stakeholders emerged as key components of a successful transition. NACDS will continue to advocate to ensure CMS provides suitable oversight of state implementation, and will keep lines of communication open with the agency on the issue.