White Guide and Orange Guide Formatting Project - Pfizer

Pfizer's or Greenstone’s business, marketing and promotional plans;
Orange Guide – Chapter 12: Contracting
Pfizer's or Greenstone’s bidding policy or its intent to bid or not to bid for particular
business;
Pfizer's or Greenstone’s plan to do business or not do business with particular customers;
and
Pfizer's or Greenstone’s intention to engage or not engage in particular research activities.
Discounting and Price Reporting
Generally, Pfizer and Greenstone must provide the federal government with either the largest discount
that they provide to certain eligible customers, or a minimum percentage discount as noted below.
As part of the Medicaid Drug Rebate Program, Pfizer and Greenstone must enter into a national rebate
agreement with the Secretary of the U.S. Department of Health and Human Services (HHS) for states
to receive federal funding for outpatient drugs dispensed to Medicaid patients. This rebate agreement
requires manufacturers to provide the federal government with a rebate equal to the greater of 23.1%
of Average Manufacturer Price (AMP) or the difference between a manufacturer’s Best Price (BP) and
the AMP for each unit of product paid for by State Medicaid agencies. Notably, any discount Pfizer or
Greenstone offers to eligible customers must be included in Pfizer’s or Greenstone’s price calculations
and reporting.
Average Manufacturer’s Price (AMP): means the average price paid to a manufacturer by
wholesalers for drugs distributed to retail pharmacies. This definition was clarified by the DRA Final
Rule and further modified by the Patient Protection and Affordable Care Act.
Best Price (BP): the lowest price available to any entity unless the sale, discount or other price
concession is specifically excluded by law or is provided to an entity specifically excluded by statute
or regulation. It includes cash discounts, free goods contingent upon purchase, volume discounts
and rebates.
In determining the relevant price points and corresponding rebate amounts, Pfizer and Greenstone
follow the guidance promulgated by the federal government, including the Deficit Reduction Act of
2005 (DRA), the final rule promulgated by the Centers for Medicare & Medicaid Services (CMS)
206
Rev. 09/12
Page 3 of 8