U.S. flag

An official website of the United States government

Frequently Asked Questions

Frequently Asked Questions are used to provide additional information and/or statutory guidance not found in State Medicaid Director Letters, State Health Official Letters, or CMCS Informational Bulletins. The different sets of FAQs as originally released can be accessed below.

Showing 21 to 30 of 79 results

Why is there a State column labeled XX when viewed as National Totals in the State Drug Utilization Data (SDUD)?

Since all of the states are combined in the National Totals, the state abbreviation will show on the "National Totals" and "Annual State Detail" option as "XX".

See Also:

FAQ ID:91811

SHARE URL

Why does some State Drug Utilization Data (SDUD) have an asterisk?

As CMS is obligated by the Federal Privacy Act, 5 U.S.C. Section 552a and the HIPAA Privacy Rule, 45 C.F.R Parts 160 and 164, to protect the privacy of individual beneficiaries and other persons, all direct identifiers have been removed and data that are less than eleven (11) counts are suppressed. An asterisk (*) notes suppressed data. CMS applies counter or secondary suppression in cases where only one prescription is suppressed for primary reasons, e.g. one prescription in a state. Also, if one sub-group (e.g. number of prescription) is suppressed, then the other sub-group is suppressed.

See Also:

FAQ ID:91831

SHARE URL

Is the redacted State Drug Utilization Data (SDUD) available to the public?

No. In accordance with federal laws, State Drug Utilization Data (SDUD) that has been suppressed is not available for public consumption.  As CMS is obligated by the Federal Privacy Act, 5 U.S.C. Section 552a and the HIPAA Privacy Rule, 45 C.F.R Parts 160 and 164, to protect the privacy of individual beneficiaries and other persons, all direct identifiers have been removed and data that are less than eleven (11) counts are suppressed. A checkmark in the "Suppression Used" column notes suppressed data. CMS applies counter or secondary suppression in cases where only one prescription is suppressed for primary reasons, (e.g., one prescription in a state). Also, if one sub-group (e.g., number of prescriptions) is suppressed, then the other sub-group is suppressed.

FAQ ID:91856

SHARE URL

Does the State Drug Utilization Data (SDUD) reported for each quarter's posting always include all of the quarterly data reported by states?

If the data arrives late, it may miss the quarterly posting. However, it will be included in the next quarter's web posting.

FAQ ID:91916

SHARE URL

What are the data field descriptions for the State Drug Utilization Data (SDUD)?

For current versions of MDRP File Formats/Data Definitions, please refer to: https://www.medicaid.gov/medicaid/prescription-drugs/medicaid-drug-rebate-program/medicaid-drug-rebate-program-mdrp-file-formats-data-definitions-and-medicaid-drug-programs-mdp-email-communications/index.html

See Also:

FAQ ID:91956

SHARE URL

If a state can prove that they are under the aggregate limits of AAC and PDF and have strong participation by pharmacies, are they required to adopt the AAC and PDF reimbursement methodology at the individual claim level?

All states are required to adopt the AAC and professional dispensing fee methodology; however, it is not required to be adopted at the individual claim level, but in the aggregate. In accordance with the regulatory requirements at 42 CFR 447.512(b), the state is responsible for establishing a payment methodology, that must not exceed, in the aggregate, payment levels that the agency has determined by applying the lower of the AAC plus a professional dispensing fee or the providers' usual and customary charges to the general public. In conjunction with this the state is also responsible to ensure that pharmacy reimbursement is consistent

Supplemental Links:

with the requirements of section 1902(a)(30)(A) of the Act, which specify that provider reimbursement rates should be consistent with efficiency, economy, and quality of care while assuring sufficient beneficiary access.

FAQ ID:94691

SHARE URL

If a state is already using actual acquisition cost (AAC) as their reimbursement methodology, does the state need to file a State Plan Amendment (SPA) or provide assurances that the current formula meets requirements established in the final rule? Is there a requirement for such states to file a SPA to provide assurance that the state's current dispensing fee amount meets the requirements of the final rule?

If a state is already making payment for prescription drugs under its state plan based on AAC, it may continue to use that methodology. However, if a state decides to change its AAC model of reimbursement, (e.g., the state decides to use the National Average Drug Acquisition Cost (NADAC) instead of a state survey to implement a payment methodology based on AAC), the state must submit a new SPA through the formal SPA process for review.

Additionally, the state should review its currently approved professional dispensing fee (PDF) to determine if, in light of the regulation (42 CFR 447.518), the PDF needs to be revised and a SPA needs to be submitted. The state does not have to submit a new SPA to provide assurance that its dispensing fee is reasonable.

Furthermore, we expect that all states, even those currently operating under an AAC reimbursement methodology, will evaluate their current state plans to determine if a SPA will be required to comply with the reimbursement requirements (including, but not limited to, AAC, PDF, 340B and the federal upper limits (FULs)).

Supplemental Links:

FAQ ID:94671

SHARE URL

Will there be an annual review of PDFs that are required as part of SPA approvals?

No, CMS will not perform an annual review of PDFs; however, states must consider both the ingredient cost reimbursement and the PDF reimbursement when proposing changes to ensure that total reimbursement to the pharmacy provider is calculated in accordance with requirements of section 1902(a)(30)(A) of the Act.

Supplemental Links:

FAQ ID:94676

SHARE URL

Will CMS be providing guidance to states to ensure that states include reasonable components in their cost of dispensing survey?

To the extent that a state is conducting a cost of dispensing survey, it should be a transparent, comprehensive, and well-designed tool that addresses a pharmacy provider's cost to dispense the drug product to a Medicaid beneficiary. States have the flexibility to set PDFs, including using national or regional data from another state and we do not require that a state use a specific standard or methodology such as a survey to do so.

Further, states are not required to use a specific formula or methodology such as a cost study or use an inflation update where cost studies are not conducted; however, the burden is on each state to ensure that pharmacy providers are reimbursed in accordance with the requirements in section 1902(a)(30)(A) of the Act. CMS will review each SPA submission against these standards (see 81 FR 5311).

Supplemental Links:

FAQ ID:94681

SHARE URL

After a state evaluates changing reimbursement to actual acquisition cost plus an increased PDF and the state determines that the total cost of their pharmacy reimbursement will be increased compared to current costs, will CMS allow an adjustment in the PDF that would result in a cost neutral outcome?

The intent of the new reimbursement methodology requirements is not necessarily to result in a cost neutral outcome. The requirements are to more accurately reflect the pharmacy providers' actual prices paid to acquire drugs and the professional services required to fill a prescription. Each state's AAC reimbursement methodology and proposed professional dispensing fee will be reviewed through the SPA process to ensure they are meeting the requirements of this final rule.

Supplemental Links:

FAQ ID:94686

SHARE URL
Results per page