If a state is using a reimbursement methodology based on AAC, does it still have to conduct an aggregate FUL analysis? Or, can it be assumed that they are below the aggregate?

Not necessarily. In the case where a state is using the NADAC to meet the AAC reimbursement benchmark, for drugs that have a FUL calculated, states would generally not exceed the FUL aggregate. However, if a state uses another reimbursement benchmark to establish their AAC model of reimbursement, such as a state survey of retail prices, the state cannot assume that the FUL aggregate will not be exceeded.

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