Drug Price Transparency & Reporting
Price transparency program design and support.
Drug Price Transparency & Reporting
Baker Tilly’s life sciences practice helps clients navigate the increasingly complex patchwork of state and local drug pricing laws through our pricing strategy, price reporting and transparency services.
Drug price transparency
Across the healthcare delivery system, there is pressure to bend the cost curve through lowering prescription drug prices. In the absence of a federal program, state and local governments are adopting drug price transparency laws that require life sciences companies to disclose specific strategic and commercial pricing information. Similar to an earlier generation of laws that focused on a product’s average manufacture price (AMP), the laws that have been recently passed or that are under consideration are generally focused on a product’s wholesale acquisition cost (WAC).
The growth in the number of state and local governments adopting price transparency laws is similar to the way spend transparency rolled out across the country over a decade ago and create an intricate and varied regulatory environment.
The details and complexity of pricing laws differ between jurisdictions. Some laws protect information from public disclosure by explicitly making trade secret protections available, while other laws simply require regulators to keep certain information confidential. As a result, a comprehensive drug price transparency plan must take into account strategic price positioning and tactical data disclosure required by the various laws.
Price transparency laws
Some of the most common requirements of price transparency laws include:
- Notice to payers and other stakeholders prior to introduction of a new product with a WAC above a specific amount
- Providing commercial details to regulators for new products with a WAC price that exceeds a specific threshold
- Reporting detailed information to the state if the WAC price of a product is raised above a specific amount within a certain time period (e.g., 16% or more within two years)
