AMP True-Up
Definition
An AMP true-up occurs when a manufacturer revises its previously reported AMP for a specific time period. Because the 340B ceiling price is calculated from AMP, a restatement of AMP changes the ceiling price retroactively. If the restated AMP results in a lower ceiling price than what covered entities were charged during the affected period, the manufacturer must refund the difference.
AMP true-ups are a mechanism for ensuring pricing accuracy over time. They reflect the reality that AMP calculations can be complex and may require revision as additional data becomes available. Covered entities that participate in the 340B Prime Vendor Program or have robust pricing monitoring may be better positioned to identify and collect refunds resulting from AMP true-ups.
AMP true-ups are relatively infrequent but can result in meaningful refunds for covered entities with high drug purchase volumes.
Frequently Asked Questions
Why AMP True-Up Matters
AMP true-ups can result in refunds for covered entities that paid above the corrected ceiling price. Covered entities with robust pricing monitoring are better positioned to identify and collect these refunds.
How Virtue 340B Uses It
Virtue 340B monitors pricing accuracy for covered entity clients and helps identify situations where AMP restatements may have resulted in overpayments.