The Centers for Medicare and Medicaid Services has opened a public comment window on the survey program that quietly sets a reference price many employer health plans use to reimburse prescription drugs. In a September 1 Federal Register notice, CMS proposed continuing its National Average Drug Acquisition Cost survey, which polls roughly 72,000 pharmacies each month on what they actually pay to acquire drugs. States use NADAC data to set Medicaid reimbursement rates, and a meaningful share of employer-sponsored health plans reference the same figures when negotiating pharmacy benefit terms.
This matters to benefits leaders because it is a rare, direct opening to influence a pricing input most plans treat as a fixed government number rather than something they can weigh in on. CMS is specifically asking for input on “ways to enhance the quality, utility and clarity of the information to be collected,” according to the notice, and on whether the current pharmacy sample and cost figures need expansion. Comments are due November 2, giving benefits and procurement teams roughly two months to respond before CMS finalizes the next survey cycle.
The original insight is that this comment period arrives while employer health costs are already under unusual pressure from multiple directions, and NADAC is one of the few levers with a public comment process attached to it. Most of the numbers driving 2027 premium increases, insurer negotiations, network pricing, are set in private contracts with no comment window at all. A plan sponsor who wants NADAC to capture more of the discounts specialty pharmacies actually negotiate has a concrete, dated opportunity to say so, which is not true of nearly anything else in the broader employer health cost problem benefits teams are already fighting or of the wellness-linked incentive rules covered in the Department of Labor’s recent tobacco wellness guidance.
Source: Federal Register
