NADAC Survey: What is It and Do I Need to Respond?

Pharmacies that receive a National Average Drug Acquisition Cost (NADAC) Survey frequently contact PAAS National® for information and guidance. While this survey remains voluntary, pharmacies may want to take a minute to understand what the survey is about.

The Affordable Care Act required that Medicaid programs shift pharmacy reimbursement to an acquisition cost-based model. CMS Final Rule (CMS-2345-FC) set a compliance date for State Medicaid Programs to be effective no later than April 1, 2017.

The NADAC file was created to provide pricing files for state Medicaid agencies to utilize when creating their acquisition cost-based pricing methods for Fee-for-service (FFS) Medicaid plans.

CMS has contracted Myers & Stauffer, LC to conduct these retail pricing surveys. Out-patient pharmacies are randomly selected to receive these surveys, requesting invoices for purchases made over a one-month period. The data collected from these invoices are used to update the NADAC file on a weekly basis.

Again, these surveys are currently voluntary, and pharmacies are under no obligation to respond. This however may change with a newly introduced bill, Drug Pricing Transparency in Medicaid Act of 2023 (H.R. 1613). If passed, this bill would not only make the surveys mandatory for pharmacies to respond but includes many updates to ban spread pricing in State Medicaid Plans. PAAS will keep you informed if, and when this bill passes.

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  • NADAC files are published monthly here
  • Consider responding if you are being paid below your cost on Medicaid claims; your actual costs can be added to the survey data
  • Pharmacies may want to consider requesting a Non-Disclosure Agreement from Myers & Stauffer LC
  • Steps to take with your documents if responding
    • Print “Confidential” on each invoice page
    • Only include the documents requested, no PHI should be included
  • Contact Myers & Stauffer LC helpdesk with any additional questions (855) 457-5264

Dana Westberg, CPhT