Public Law 102-585, Veterans Health Care Act of 1992
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On this page:
Interim Agreements | Master Agreement & Pharmaceutical Pricing Agreement
Regulations & Guidance | 2016 Covered Drug Pricing Request for Modification Process
2015 Timeline for 2016 Covered Drug Pricing Updates
The 2015 Public Law Pricing Update Season FSS, NAC & PBM regulations & guidance are now available for review!
Stipulated in Public Law 102-585, Section 603 all brand name drugs must be made available for purchase under the 65 I B Schedule program at a not to exceed price as a condition for receiving payment from certain entities.
All affected suppliers must submit a proposal for a VA Schedule contract. We developed the Interim Agreement (IA) process to bridge the gap while negotiating a VA Schedule contract. The IA gives both the FSS Service and the supplier the time needed to move through the new offer review process, negotiations, and award of a new contract while allowing the supplier to immediately meet the requirements of P. L. 102-585.
This year we streamlined our interim agreement process for new suppliers and/or suppliers of new brand name drugs. As part of this process, suppliers are required to provide our office with
- All relevant information regarding the affected drugs;
- Relevant information on the company adding the items;
- Contact information for the company adding the items; and
- Registration in the Government’s System Award Management (SAM) database
Upon receipt of this information we will provide your company with the relevant paperwork required to execute an interim agreement. Submit all interim agreement related inquires, comments, and documentation to firstname.lastname@example.org
Master Agreement & Pharmaceutical Pricing Agreement
In addition to meeting the requirements of the 65 I B Schedule program, manufacturers of covered drugs must enter in to a Master Agreement (MA) and a Pharmaceutical Pricing Agreement (PPA) with the VA.
- Master Agreement.The Master Agreement stipulates that covered drugs must be made available on the VA Schedules program and outlines the vendor’s responsibilities & obligations associated with the PL. Specifically, the MA instructs vendors to enter into a Pharmaceutical Pricing Agreement and requires them to submit non–FAMP data to the VA to establish federal ceiling prices (FCP). The terms and conditions of this agreement are non–negotiable and the same for all 65 I B contractors. This is an evergreen document and, as such, does not expire.
- Pharmaceutical Pricing Agreement.Through the Pharmaceutical Pricing Agreement, contractors agree that the annual FCP for each covered drug constitutes the maximum price that may be charged to the Government. Through Addendum A to the PPA, contractors provide a complete list of their available covered drugs. This list includes the product names, all applicable NDC numbers, and the current FCP for each drug. Contractors are required to update the PPA annually during the Public Law season.
P.L. 102-585 Regulations & Guidance
P.L. 102-585 2016 Covered Drug Pricing Request for Modification Process
Download the 2016 P.L. 102-585 Covered Drug Pricing Request for Modification. We will only process RFMs submitted using this year’s forms.
Send requests email@example.com and cc your assigned contract specialist. To ensure receipt of your firm’s request for modification, the Subject Line must have the following identifying information: RFM-Contract Number-PL2016 (e.g. RFM-V797P/D-5555X-PL2016)
Modification requests submitted with missing or inaccurate information; or changes to the spreadsheet submitted after December 3, 2015 may have an adjusted effective date of January 15, 2016 or later. As a result, your firm may be subject to the penalties outlined in PL 102-585.
2015 Public Law Timeline for 2016 Covered Drug Pricing Updates
This is an abbreviated timeline. See the PBM, OGC & FSS Guidance for full instructions and due dates.
10/22…Receive Excel workbook with covered drug NDCs from PBM
10/30…Report & describe modifications in existing methodology used to calculate non–FAMP to PBM, OGC, and OIG
11/05…FSS Instruction Letter submitted to vendor by NAC.
11/15…Vendors required to submit pricing calculations to PBM on or before November 15, 2015.
October, November, & December…Verification of FCP by PBM and forwarded to CO.
12/03…The authorized official that signed your firm’s PPA Addendum for 2016 FCPs (or an authorized successor), must prepare and sign a new PPA addendum. Submit a properly prepared request for modification package to incorporate updated pricing into your FSS contract. To ensure receipt of your firm’s request for modification, the Subject Line must have the following identifying information: RFM-Contract Number-PL2016 (e.g. RFM-V797P/D-5555X-PL2016). Email your completed package to:firstname.lastname@example.org and assigned contract specialist.
12/31…Vendors to provide updated PPA Addendum to CO on or before December 31, 2015.