Pharmacy Pricing

We calculate the Affordable Care Act Federal Upper Limit (FUL) data according to the Medicaid Covered Outpatient Drug final regulation with comment. We update FUL values monthly, and they are effective on the first day of the month following the publication. States have up to 30 days after the effective date to implement the FUL. Further information on the FUL program can be found on the Federal Upper Limit page.

We update the National Average Drug Acquisition Cost (NADAC) data and comparison data weekly. Each month we post new data, including findings from the previous month’s survey and weekly price changes that have occurred before the release of the next month’s NADAC data.

Beginning with the December 2024 monthly NADAC rate updates, which will be effective 12/18/2024, CMS is implementing a temporary, short-term measure intended to address recent rate volatility occurring as a result of fluctuations in survey participation.  Specifically, monthly NADAC updates for generic drugs will be calculated using a three-month moving average.  This three-month moving average will utilize the individual calculated monthly average acquisition costs from the most recent three months and become the updated generic NADAC rate.  CMS is adopting a three-month moving average in order to moderate monthly rate volatility while also ensuring that rates remain responsive to change in market conditions.

The three-month moving average approach will not be applied to NADAC rates for brand drugs.  Brand drugs utilize a separate time frame for monthly rate calculations and the application of a moving average methodology is not necessary to prevent rate volatility at this time.

The use of the three-month moving average for generic drugs will continue until further notice.  To address the potential for future rate volatility on a more permanent basis, CMS plans to solicit stakeholder input regarding the NADAC methodology. 

The NADAC Monthly file is produced on the first Monday on or after the 15th of each month. All other files during the calendar month are weekly postings.

For more information on the fields in the NADAC data, please review the NADAC Data Field Definitions. Find more NADAC information on the Survey of Retail Prices page. 

This comparison data, published on a weekly basis, identifies drug products with current NADAC rates that have been replaced with new rates since the current NADAC weekly reference file was posted. This file will not be inclusive of all new and terminated NDCs. For more information on the data fields used in the weekly comparison, please review the NADAC Week to Week Data Field Definitions.

This table lists first time NADAC rates for drug products that have not had a NADAC rate previously. It augments the weekly published NADAC data and comparison files. These drug products have been incorporated in the weekly NADAC data and comparison files. The purpose of these files is to highlight those drug products that have not had a NADAC rate in the past. This table will be updated monthly with previous monthly listings available. 

This pricing comparison table illustrates the relationship of published pricing benchmarks commonly used by state Medicaid agencies and the Medicare program for ingredient cost reimbursement of blood disorder products to the average acquisition cost (AAC) for these products.

Although these specialty blood disorder products are not required to be reimbursed at AAC, CMS believes that this table will be helpful for states to use for analyzing, understanding and monitoring the relationship of AAC pricing to commonly used pricing benchmarks.

When evaluating the adequacy of total Medicaid reimbursement for blood disorder product claims, the professional dispensing fee should be adequate to assure access consistent with 1902(a)(30)(A). Guidance to states concerning Medicaid coverage and reimbursement for clotting factors, anti‐hemophilia drugs and other services provided to Medicaid beneficiaries with blood disorders can be found in the Medicaid Drug Rebate Program Notice, State Release No. 182.

When proposing a change to a reimbursement methodology, state Medicaid programs are required to submit a State Plan Amendment (SPA) to the Centers for Medicare & Medicaid Services (CMS) for review and approval.

This table will be updated semi-annually.