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Office of Acquisition and Logistics (OAL)

Public Law 102-585, Veterans Health Care Act of 1992

Tel: (708) 786-7737 Fax: (708) 786-5828 Contacts Survey

Public Law (PL) 102-585, Section 603 requires covered drug manufacturers to have a VA Schedule contract as a condition of receiving payment from certain entities.

Important Notice

The 2015 Public Law Pricing Update Season FSS, NAC & PBM regulations & guidance are now available for review!

Interim Agreements

Stipulated in Public Law 102-585, Section 603 all brand name drugs must be made available for purchase under the 65 I B Schedule program at a not to exceed price as a condition for receiving payment from certain entities.

All affected suppliers must submit a proposal for a VA Schedule contract.  We developed the Interim Agreement (IA) process to bridge the gap while negotiating a VA Schedule contract.  The IA gives both the FSS Service and the supplier the time needed to move through the new offer review process, negotiations, and award of a new contract while allowing the supplier to immediately meet the requirements of P. L. 102-585.

This year we streamlined our interim agreement process for new suppliers and/or suppliers of new brand name drugs.  As part of this process, suppliers are required to provide our office with

  • All relevant information regarding the affected drugs;
  • Relevant information on the company adding the items;
  • Contact information for the company adding the items; and
  • Registration in the Government's System Award Management (SAM) database

Upon receipt of this information we will provide your company with the relevant paperwork required to execute an interim agreement.  Submit all interim agreement related inquires, comments, and documentation to the

Master Agreement & Pharmaceutical Pricing Agreement

In addition to meeting the requirements of the 65 I B Schedule program, manufacturers of covered drugs must enter in to a Master Agreement (MA) and a Pharmaceutical Pricing Agreement (PPA) with the VA.

  • Master Agreement.The Master Agreement stipulates that covered drugs must be made available on the VA Schedules program and outlines the vendor’s responsibilities & obligations associated with the PL.  Specifically, the MA instructs vendors to enter into a Pharmaceutical Pricing Agreement and requires them to submit non–FAMP data to the VA to establish federal ceiling prices (FCP).  The terms and conditions of this agreement are non–negotiable and the same for all 65 I B contractors.  This is an evergreen document and, as such, does not expire.
  • Pharmaceutical Pricing Agreement.Through the Pharmaceutical Pricing Agreement, contractors agree that the annual FCP for each covered drug constitutes the maximum price that may be charged to the Government.  Through Addendum A to the PPA, contractors provide a complete list of their available covered drugs.  This list includes the product names, all applicable NDC numbers, and the current FCP for each drug.  Contractors are required to update the PPA annually during the Public Law season.

P.L. 102-585 Regulations & Guidance

PL 102-585, Section 603 Regulations
Pharmacy Benefits Management Services 2015 PBM Annual Guidance (FINAL including CPI-U data)

2015 FCP Guidance for New Covered Drugs

Non-FAMP New Product Request Template
National Acquisition Center 2015 NAC Annual Guidance (Public Law Policy Group)
Federal Supply Schedule Service 2015 FSS Annual Guidance

2015 P.L. 102-585 Covered Drug Pricing Request for Modification

2015 P.L. 102-585 PPA Addendum A

P.L. 102-585 Frequently Asked Questions
Public Law Core Team

FSS Public Law Modifications
Index of Public Law Correspondence (1992 — Present)

Public Law Correspondence Archive (1992 — Present)
FSS Public Law FAQs

TRRx Sales & Non–FAMP FAQs

P.L. 102-585 2015 Covered Drug Pricing Request for Modification Process

Download the 2015 P.L. 102-585 Covered Drug Pricing Request for Modification.  We will only process RFMs submitted using this year’s forms.

Do not send requests directly to your permanent contract specialist.  To ensure receipt of your firm’s request for modification, the Subject Line must have the following identifying information:

RFM-Contract Number-PL2015 (e.g. RFM-V797P/D-5555X-PL2015)

Continue to send all non-Public Law modifications to the FSS Help Desk,


Modification requests submitted with missing or inaccurate information; or changes to the spreadsheet submitted after December 3, 2014 may have an adjusted effective date of January 15, 2015 or later.  As a result, your firm may be subject to the penalties outlined in PL 102-585.


PL 102-585 RFM package must include the 2014 request for modification form, the completed pre-populated pricing spreadsheet, and Addendum A to the PPA

2014 Public Law Timeline for 2015 Covered Drug Pricing Updates

This is an abbreviated timeline.  See the PBM, OGC & FSS Guidance for full instructions and due dates.

2013 PL Timeline for 2014 Covered Drug Pricing Updates


10/22…Receive Excel workbook with covered drug NDCs from PBM
10/30…Report & describe modifications in existing methodology used to calculate non–FAMP to PBM, OGC, and OIG
10/30…Report any disputes of the covered drug’s non–FAMP for 7/1/2013 — 9/30/2013 (3Q non–FAMP Old)
11/15…Submit annual non–FAMP (10/1/2014 — 9/30/2014) and 3Q non–FAMP New (July 1, 2014 — September 30, 2014) to PBM
11/17…PBM will begin calculating changes in non-FAMP pricing, additional discounts, and 2015 FCP.  You will have two business days to dispute or resubmit calculations related to the 2015 FCPs to PBM, OGC, and OIG.
12/03…The authorized official that signed your firm’s PPA Addendum for 2015 FCPs (or an authorized successor), must prepare and sign a new PPA addendum.  Submit a properly prepared request for modification package to incorporate updated pricing into your FSS contract.  To ensure receipt of your firm’s request for modification, the Subject Line must have the following identifying information: RFM-Contract Number-PL2015 (e.g. RFM-V797D-12345X-PL2015).  Email your completed package