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VA Issues Guidance on Treatment of “Maximum Fair Price” in Statutory Price Calculation
Earlier this month the Department of Veterans Affairs Public Law Policy Group (VA) posted a “Supplemental” Dear Manufacturer Letter (DML) that addresses how manufacturers should treat sales at Inflation Reduction Act of 2022 (IRA) maximum fair prices (MFPs) in statutory Non-Federal Average Manufacture Price (Non-FAMP) calculations. Non-FAMP is the weighted average wholesaler price used in calculating the Federal Ceiling Price, which serves as a cap to Federal Supply Schedule (FSS) contract…
By: Hogan Lovells