Office of Procurement, Acquisition and Logistics (OPAL)
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 & Annual Guidance | 2020 Covered Drug Pricing Request for Modification Process
2019 Timeline for 2020 Covered Drug Pricing Updates
The 2020 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 email@example.com
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
Since implementation of P.L. 102-585, section 603, VA has issued numerous policy documents in the form of Dear Manufacturer Letters (DML). DMLs provide insight into VA’’s current thoughts on issues and offer guidance and best practices with respect to the administration, promulgation, and compliance with the law. Download the archive all DML’s issued by VA since 1992.
|Pharmacy Benefits Management Services||2020 PBM Annual Guidance
2020 FCP Guidance for New Covered Drugs
Non-FAMP New Product Request Template
|Federal Supply Schedule Service||2020 FSS Annual Guidance
2020 P.L. 102-585 Covered Drug Pricing Request for Modification
2020 PPA Addendum
|Public Law Core Team
FSS Public Law Modifications
P.L. 102-585 2019 Covered Drug Pricing Request for Modification Process
Download the 2020 P.L. 102-585 Covered Drug Pricing Request for Modification. We will only process RFMs submitted using this year’s forms.
Send requests firstname.lastname@example.org 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-PL2020
Modification requests submitted with missing or inaccurate information; or changes to the spreadsheet submitted after December 4, 2019 may have an adjusted effective date of January 15, 2020 or later. As a result, your firm may be subject to the penalties outlined in PL 102-585.
2019 Public Law Timeline for 2020 Covered Drug Pricing Updates
This is an abbreviated timeline. See the PBM and FSS Guidance for full instructions and due dates.
10/01…FSS Instruction Letter submitted to vendor by NAC.
10/10…PBM Dear Manufacturer Letter (DML) letter submitted to vendors by PBM.
11/15…Vendors required to submit pricing calculations to PBM on or before November 15, 2019.
October, November, & December…Verification of FCP by PBM and forwarded to CO.
12/04…The authorized official that signed your firm’s PPA Addendum for 2020 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 (e.g. RFM Contract Number PL2020). Email your completed package to:email@example.com and assigned contract specialist.
12/31…Vendors to provide updated PPA Addendum to CO on or before December 31, 2019.