First Databank (FDB) is committed to serving our customers and the healthcare industry by publishing the best available drug and drug pricing information available.
This information includes drug pricing such as Average Acquisition Cost (AAC), Wholesale Acquisition Cost (WAC), Direct Price, Suggested Wholesale Price (SWP), Federal Upper Limit (FUL) , and Average Manufacturer Price (AMP), as well as our clinical drug information.
As you likely know, FDB discontinued the publication of Blue Book Average Wholesale Price (BBAWP) on September 28, 2011.
FDB remains actively engaged with the public and private sector in efforts to gather and publish additional drug pricing data elements, as available, and to facilitate the establishment of sustainable drug reimbursement benchmarks.
Recent developments in the industry suggest that a new acquisition cost-based standard may be emerging:
The Department of Health and Human Services Secretary, Kathleen Sebelius, announced in February 2011 that the Centers for Medicare and Medicaid Services (CMS) will be conducting a nationwide acquisition cost survey, National Average Drug Acquisition Cost (NADAC), with results expected by the end of the calendar year;
A July 2011 report by the Office of the Inspector General (“Replacing Average Wholesale Price: Medicaid Drug Payment Policy”) recommends that that CMS “develop a national benchmark that accurately estimates acquisition cost and encourage States to consider it when determining Medicaid reimbursement for prescription drugs.” In fact, according to the OIG report:
- “Forty-four States would like CMS to develop a national benchmark to set Medicaid reimbursement for prescription drugs. Most States (44 of 51) would prefer that CMS develop a single national benchmark to set Medicaid reimbursement rates. Twenty-four States specified that they want a benchmark based on pharmacy acquisition costs.”
Alabama, Oregon, and Idaho have converted their Medicaid program reimbursement to an acquisition cost basis, and California, New York, Iowa, and Colorado have indicated their intention to do likewise.
FDB will continue to monitor the marketplace closely to incorporate relevant pricing benchmarks as they become available.
Wholesale Acquisition Cost (WAC)
(previously referred to as Net Wholesale Price) as published by First Databank represents the manufacturer's (for purposes of this Drug Price Policy, the term "manufacturer" includes manufacturers, repackagers, private labelers and other suppliers) published catalog or list price for a drug product to wholesalers as reported to First Databank by the manufacturer. WAC does not represent actual transaction prices and does not include prompt pay or other discounts, rebates or reductions in price. First Databank does not perform any independent investigation or analysis of actual transaction prices for purposes of reporting WAC. First Databank relies on manufacturers to report or otherwise make available the values for the WAC data field.
Direct Price (DP)
as published by First Databank represents the manufacturer's published catalog or list price for a drug product to non-wholesalers as reported to First Databank by the manufacturer. Direct Price does not represent actual transaction prices and does not include prompt pay or other discounts, rebates or reductions. First Databank does not perform any independent investigation or analysis of actual transaction prices for purposes of reporting Direct Price. First Databank relies on manufacturers to report or otherwise make available the values for the Direct Price data field.
Suggested Wholesale Price (SWP)
as published by First Databank represents the manufacturer's suggested price for a drug product from wholesalers to their customers (i.e., retailers, hospitals, physicians and other buying entities) as reported to First Databank by the manufacturer. SWP is a suggested price and does not represent actual transaction prices. First Databank relies on manufacturers to report or otherwise make available the values for the SWP data field.
Average Manufacturer Price (AMP)
As defined by 42 U.S.C. 1396r–8(k)(1) the AMP is “the average price paid to the manufacturer for the drug in the United States by—(i) wholesalers for drugs distributed to retail community pharmacies; and (ii) retail community pharmacies that purchase drugs directly from the manufacturer.”
The Centers for Medicaid and Medicare Services (CMS) have recently begun publishing weighted average AMPs for generic categories along with “draft” Federal upper limit (FUL) prices, but as of January 2012, have not issued final AMP data
Federal Upper Limit (FUL)
(Previously referred to as Federal Financing Participation Upper Limits—FFPUL) FUL prices, also defined in 42 U.S.C. 1396r–8, at subsection (e), are established “for each multiple source drug for which the FDA has rated three or more products therapeutically and pharmaceutically equivalent.” The Affordable Care Act of 2010 redefined the methodology for calculating FULs at “no less than 175 percent of the weighted average (determined on the basis of utilization) of the most recently reported monthly average manufacturer prices for pharmaceutically and therapeutically equivalent multiple source drug products that are available for purchase by retail community pharmacies on a nationwide basis.” FULs calculated by the pre-existing formula are already an existing Price Type in NDDF Plus, and will be replaced by the revised FULs once CMS finalizes the new values.
First Databank relies on manufacturers and other third parties to report or otherwise make available the values for the above referenced drug price data fields and, as a result, such data fields are subject to the availability of the relevant information. First Databank reserves the right, in its sole discretion, to change this Drug Price Policy without notice. Please check back and refer to First Databank's Drug Price Policy as you review and utilize the pricing information contained in First Databank's products.
Please contact Customer Service at 800-633-3453 if you have any questions.