Drug pricing transparency
Drug pricing transparency requirements are landing directly on Defense and Government Contracting firms through federal procurement channels, not just pharmaceutical supply chains. The Defense Contract Audit Agency and the Department of Defense Office of Inspector General have both signaled heightened scrutiny of pharmaceutical line items in government contracts, and the Federal Acquisition Regulatory Council's ongoing work to align FAR clauses with drug pricing disclosure mandates is putting new obligations on prime contractors who source or resell covered drugs. Compliance teams are currently mapping subcontractor drug procurement against FAR Part 12 commercial item determinations to assess where transparency gaps could trigger audit findings.
Watch
- FAR Council proposed rule on drug pricing disclosures in federal supply schedules
- DCAA audit guidance expanding review of pharmaceutical cost allowability under cost-type contracts
- OIG work plan items targeting drug procurement markups in DoD medical logistics contracts
- State-level price transparency laws that reach government contractor subsidiaries operating as commercial entities
Recent material activity in Defense & Government Contracting
Active monitoring in place across Defense & Government Contracting. Material developments related to drug pricing transparency will appear here as they are published.