ACI 17th Annual “BIG FOUR” Pharmaceutical Pricing Boot Camp

Partner Joy Sturm presented at the “BIG FOUR” Pharmaceutical Pricing Boot Camp on U.S. Government Contract Price Calculations and the Inflation Reduction Act on 2 May at 2:45 p.m. ET

In this session panelists discussed the VHCA calculations, from nuts and bolts to complex issues, and also provided a timely analysis of the IRA and how it “imports” the Non-FAMP into the new IRA pricing program.

The panel provided insights into:

PART I: IRA & VHCA Section 603 Interconnectedness

  • Summary of IRA program and drug price negotiation / MFP
  • Leveraging of Non-Federal Average Manufacturers Price (Non-FAMP)

PART II: VHCA Section 603 Non-FAMP & FCP Calculations and Reporting

  • The Framework for Calculation and Reporting
  • “Nuts and bolts” of the Non-FAMP and FCP calculations
  • Annual and quarterly reporting requirements and their intersection with FSS contract
  • Best practices for obtaining data necessary for Non-FAMP calculation
  • Overlapping issues as between Medicaid (BP & AMP) and VHCA (Non-FAMP)


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