- New October 2025
Title 22, §8736, requires the MHDO to produce and post on its publicly accessible website an annual Drug Price Transparency Report. The content of the report is to include information developed from the disclosures submitted to MHDO per the requirements of 90-590 Chapter 570, Uniform Reporting System for Prescription Drug Price Data Sets, from manufacturers, wholesale drug distributors and pharmacy benefits managers, referred to as reporting entities. Specifically, the report provides information on trends in the cost of prescription drugs, analysis of manufacturer prices and price increases, the major components of prescription drug pricing along the supply chain, and the impacts on insurance premiums and cost sharing and any other information the MHDO determines is relevant to providing greater consumer awareness of the factors contributing to the cost of prescription drugs in the State.
Under contract with MHDO, Ten2Eleven Business Solutions provided MHDO technical support in the preparation of this report.
This is MHDO's Fifth Annual Report.
Previous reports can be found on our web page: Rx Drug Pricing Transparency - Historical
This is MHDO’s fifth annual report and includes an additional year of data for CY 2023. A key finding that has been consistent across all prior reports is that for generic drugs, the Average Wholesale Price (AWP - the value from which payer contracted rates are set) is often set to a much higher value than the Wholesale Acquisition Cost (WAC – the list price charged by manufacturers to wholesalers before rebates). AWP values for generic drugs are often set by manufacturers as a discount from the WAC value of the equivalent brand drug as it exists at the time the first generic product is introduced to market. Once set, manufacturers do not update the value of AWP as the value of WAC changes over time. As a result, while WAC prices differ between generic manufacturers, AWP prices show very little variation and are often the same across manufacturers. The result is that payers pay contracted rates that are effectively the same across all equivalent generic drug products, even though the cost to the pharmacy for these drugs varies greatly from one manufacturer to the next. In an analysis of generic drugs with WAC price reductions during 2023, the AWP value had an average markup from WAC of 2,165.16% after WAC decreases were applied.
Pharmacies can reduce the cost of drug inventory by acquiring generic products from manufacturers with the lowest WAC. However, payers do not receive a corollary benefit from lower WAC prices when AWP, the basis for pharmacy reimbursement, remains static across generic manufacturers. Instead, the reductions the manufacturers make in WAC result in a higher margin to the pharmacy – in some instances, a pharmacy receives greater income for a product than the product’s manufacturer.
The data suggest that there may be opportunities for prescription drug cost reductions in Maine if the payment for prescription drugs more closely aligned with actual drug acquisition costs.
To jump to an area of specific interest in the report click the links below:
Highlights and conclusions of MHDO’s fifth annual report include:
Year over year observations:
Primary entities in the pharmaceutical supply chain include:
In 2023, payments for retail pharmacy claims reported to the MHDO for all prescription NDCs per the requirements in 90-590 Rule Chapter 243, Uniform Reporting System for Health Care Claims Data Sets, was approximately $3.0B, representing approximately 23% of all payments reported to MHDO. A breakdown of pharmacy claims by payer type is provided in the table below.
The top 10 most costly drug families based on MHDO data in 2023 are shown in the table below. Drug families are groups of drugs that share a unique generic drug description (non-trade name) and drug form. In total, the top 10 most costly drug families had paid amounts of $820.7M across 468,715 claims. The top 10 most utilized drug families (shown in the second table) had total paid amounts of $60.8M across 2.9M claims.
The top 10 most utilized drug families based on MHDO data in 2023 are shown in the table below
The top 10 drug families with the highest year over year paid amount increase in 2023 based on MHDO data are shown in the table below.
MHDO used publicly available prescription drug pricing data to analyze changes in the wholesale acquisition costs of drug products set by pharmaceutical manufacturers over the previous five years for all drug products with at least one claim reported in the MHDO’s data during 2023 (active NDCs – (see footnote 5)).
The analysis shows that during the five-year period:
See the table and chart below.
WAC Change Statistics by Year
Of 44,803 active brand and generic prescription NDCs in the pharmaceutical market, Mainers filled prescriptions for 31,433 drugs in 2023. Less than 1% of these drugs (56 drugs total – 45 brand drugs, and 11 generic drugs with a beginning wholesale acquisition cost of $10 per pricing unit) had increases in the wholesale acquisition costs in 2023 of more than 20%.
Brand and Generic Drug Cost Differentiation for Multisource Drug Products
MHDO used the pricing component data submitted by manufacturers, wholesale distributors and pharmacy benefit managers (referred to as reporting entities) per the reporting requirements in 90-590 Chapter 570, Uniform Reporting System for Prescription Drug Price Data Sets, to evaluate the difference in the Wholesale acquisition cost between brand and generic drugs for products where brand and generic equivalents were available during the year (multisource drug products).
Of 47 multisource drugs (a brand drug or generic drug that is available from more than one manufacturer) reviewed, each had generic versions priced lower than their brand equivalents before and after application of changes in the wholesale acquisition costs. On average wholesale acquisition costs for generic drugs in this sample were 63.73% less than the brand name drugs.
Brand to Generic Drug Utilization in Maine
In CY 2023 the MHDO pharmacy claims data shows that 5.86% of pharmacy claims where for brand drug products when generic drugs were alternatively available.
Payments for brand name drugs reported in the MHDO pharmacy claims data made up 40.14% of total payments (includes both payer and consumer payments) for multisource drug products (see footnote 6)).
A comparison of year-over-year brand to generic drug utilization statistics is provided in the table below.
Consistent with previous reports, MHDO analyzed the pharmaceutical claims data submitted to MHDO per the requirements of 90-590 Chapter 243, Uniform Reporting System for Health Care Claims Data Sets, to evaluate the impact of both increases and decreases in the wholesale acquisition costs on actual amounts paid by payers during the reporting period.
This Analysis was limited to 2,065 drugs (specifically NDCs) that incurred a change in the WAC (both increases and decreases in the WAC) during 2023 and for which at least 10 claims were incurred both before and after the changes in the WAC.
WAC Change Impact on Payer Paid Amounts
Average Wholesale Price (AWP) & the Relationship to Payer Paid Amounts
Commercial and Medicare payers (insurance companies) engage a pharmacy benefits manager (PBM) to negotiate payment rates between the payer and the pharmacies for the drugs that the pharmacies dispense.
Negotiated payment rates are typically derived as a percentage-based discount from the average wholesale price (AWP) plus a fixed price dispensing fee. Manufacturers may provide publishers of AWP with a suggested AWP value or specify a markup value to be applied to WAC. Where manufacturers do not provide AWP guidance, the value is typically set as a 20% markup over WAC.
MHDO organized the NDCs analyzed above into brand and generic items and categorized them by source type (single source vs. multisource) to evaluate differences in pricing behaviors and methods across categories.
AWP values were also incorporated for comparison to WAC and claims paid values. Statistical outcomes of the analysis are provided in the table below. Key findings are summarized in the bullets below the table.
Key findings based on MHDO’s sample of prescription drugs with manufacturer price changes
AWP and Generic Drugs
MHDO reviewed AWP price history for the generic drugs reviewed and found that AWP values were often set by manufacturers as a discount from the WAC or AWP value of the equivalent brand drug as it existed at the time the first generic product was introduced to market. For generic drugs, AWP often does not change as the value of WAC changes over time. As a result, while WAC prices differ between generic manufacturers, AWP prices show very little variation and are often the same across manufacturers. This pricing practice differs from brand drug pricing where manufacturers typically do not provide AWP guidance resulting in a default AWP value of 120% of WAC.
Pharmacies are able to reduce the cost of drug inventory by acquiring generic products from manufacturers with the lowest WAC. However, payers do not receive a corollary benefit from lower WAC prices when AWP, the basis for pharmacy reimbursement, remains static across generic manufacturers. Instead, the reductions the manufacturers make in WAC result in a higher margin to the pharmacy – in some instances a pharmacy receives greater income for a product than the product’s manufacturer.
The MHDO analyzed payment amounts for all commercial and Medicare retail pharmacy claims for prescription fills during 2023 (see footnotes 7 & 8). Where available, MHDO incorporated National Average Drug Acquisition Cost (NADAC) values published by CMS as the assumed amount paid by pharmacies to acquire drug products that were dispensed. Where NADAC values were not available, the MHDO instead imputed WAC minus two percent (see footnote 9). NADAC and WAC values were applied to each claim on a per dispensed unit basis with acquisition cost values as of the date of the prescription fill.
In 2023, 79.95% of prescription fills for generic drugs and 21.80% of prescription fills for brand drugs (72.86% overall) had payment amounts that were more than 15% above the amount that pharmacies paid to acquire the drug dispensed.
Conversely, pharmacies were paid less than acquisition costs for 11.89% of prescription fills for generic drugs and 14.40% of prescription fills for brand drugs (12.19% overall) during 2023. The total amount by which pharmacies were paid less for drugs dispensed than the cost to acquire the drug was $44.0M for claims reimbursed under commercial and Medicare plans (see footnotes 7).
This analysis shows there are opportunities for cost reductions in Maine if the payment for prescription drugs aligned with actual drug acquisition costs while paying pharmacies at least the amount it cost to acquire the drug.
For example, if payment amounts for the claims analyzed above (small sample) were limited to 115% of a pharmacy’s actual acquisition cost (before dispensing fees), payments for prescription drugs in Maine would have been $232.2M less (9.81%) in 2023 without any reduction in WAC.
Prescription drug rebates accrue as drug products are purchased and dispensed between manufacturers, wholesale distributors, pharmacy benefits managers and payers over time and may represent a fixed amount per unit or a percentage of an agreed upon price point such as WAC.
MHDO reviewed 507 unique brand and generic drugs (specifically NDCs) for which pricing component data was submitted to MHDO per the requirements of 90-590 Chapter 570, Uniform Reporting System for Prescription Drug Price Data Sets, and commercial claims data was submitted to MHDO by payers per the requirements of 90-590 Chapter 243, Uniform Reporting System for Health Care Claims Data Sets, for the time period 2023.
A summary of the average manufacturer rebates reported to MHDO for 2023 is provided in the table below (see footnote 8).
Overall, for the subset of 507 NDCs reviewed by MHDO, the average amount paid by insurance companies and consumers after rebates was 76.15% of the average WAC amount for a given brand drug and 400.95% for a given generic drug.
Primary entities in the pharmaceutical supply chain include:
The pharmaceutical supply chain is complex with steps that include physical product acquisition as well as transactional elements triggered by contractual agreements between participants. A summary of the major supply chain components are described below:
A wholesaler’s acquisition of drug products from manufacturers is the first step in the supply chain. Typically, wholesalers purchase drug products at the WAC and store them in distribution centers until the products are later purchased by pharmacies. Contracts between manufacturers and wholesalers may provide for accrual of rebates to be paid to the wholesaler when the wholesaler later sells the product to a pharmacy. MHDO used pricing component data provided by wholesalers for calendar year 2023 as defined in 90-590 Chapter 570, Uniform Reporting System for Prescription Drug Price Data Sets, to calculate the percent of acquisition costs that are rebated from manufacturers to wholesalers on a per unit basis. Rebate percentage values are calculated at the drug (NDC) level for each wholesaler as the total rebate receivable amount divided by the total number of units sold (the total rebate receivable per unit) divided by the wholesaler’s average acquisition amount per unit for the NDC. On average wholesalers received rebate amounts of 3.50% for brand drugs and 17.62% for generic drugs (14.62% overall) when applied against acquisition cost on a per unit basis.
Acquisition of drug products by wholesalers is typically the last point in the pharmaceutical supply chain where WAC is used as the price point of a transaction. From this point forward, WAC is instead used as a basis from which price values (AWP, manufacturer rebates, etc.) are derived through the application of mark ups and/or discounts from the value of WAC.
The next step in the pharmaceutical supply chain is a pharmacy’s purchase of drug products from a wholesale distributor (wholesalers). Typically, wholesalers sell drug products to pharmacies at or below then current WAC values. Analysis of MHDO’s pricing component data shows that annual revenues generated by wholesalers from sales to pharmacies were less than amounts spent by wholesalers to acquire the products from manufacturers by 20.39% for brand NDCs and 50.36% for generic NDCs (43.98% overall). Pharmacy costs were further reduced through rebates received from wholesalers by an average of 1.34% for brand NDCs and 7.24% for generic NDCs (5.98% overall).
Wholesalers generally sell drugs to pharmacies for less than the amount they spend to purchase the drugs from manufacturers. This cost reduction develops through several factors:
The final components of the supply chain are initiated when a consumer submits a prescription at a pharmacy.
When an insured consumer submits a prescription, the pharmacy submits a claim for reimbursement to the Pharmacy Benefits Manager (PBM) contracted with the insured’s commercial payer. The PBM then adjudicates the claim to determine the amount of reimbursement to which the pharmacy is entitled based on its contracted rate with the payer. In addition, the PBM notifies the pharmacy of the share of reimbursement that should be collected from the insured at the time the prescription is filled.
Commercial payers engage PBMs to negotiate rates with pharmacies for the drugs the pharmacies dispense. As prescriptions are filled, PBMs charge payers their contracted rate less the consumer payment amount and facilitate payment to the pharmacy.
Rates negotiated between pharmacies and payers are typically derived as a percentage-based discount from Average Wholesale Price (AWP) plus a fixed price dispensing fee. Pharmaceutical Manufacturers may provide publishers of AWP with a recommended AWP value or specify a markup value to be applied to WAC. Where manufacturers do not provide AWP guidance, the value is typically set as a 20% markup over WAC (see footnote 2). The amount that a pharmacy is reimbursed by a payer (including consumer cost share) above the cost the pharmacy paid to procure the drug product can vary greatly from one NDC to another depending on the amount that AWP is marked up from WAC.
Another variable in prescription drug pricing is the method by which PBMs are paid for the services they provide. In some instances, the PBM charges the payer a contracted price for prescription drugs, and the contracted price for the prescription drugs differs from the amount the PBM pays the pharmacy – this arrangement is referred to as spread pricing. Payers, manufacturers, and pharmacies may also pay PBMs administrative fees for their services.
Analysis of MHDO’s pricing component data provided by PBMs shows that, on average, PBMs retained payments from payers in the form of spread and/or administrative fees at a rate of 9.49% above what PBMs reimbursed to pharmacies for brand NDCs and 33.70% for generic NDCs (28.54% overall).
As reported in the MHDO’s commercial claims data for the subset of 507 NDCs reviewed, and after consideration for spread pricing and/or administrative fees paid to PBMs, amounts paid by payers and consumers to pharmacies were higher than amounts paid by pharmacies to wholesalers by an average margin of 24.10% for brand NDCs and 616.33% for generic NDCs (490.17% overall). It should be noted that average margins for brand drugs are likely influenced by the impact of 340B transactions whereby wholesaler reported pharmacy acquisition costs are significantly lower than WAC while amounts paid by payers and consumers are paid at market rates. This phenomenon is less prevalent in the generic space where the difference between a manufacturer’s 340B price and WAC is less significant.
In addition to negotiating pharmacy reimbursement rates, PBMs develop and maintain drug formularies used by payers to determine the level of cost sharing for specific drugs between a payer and its members. Drugs on a formulary are divided into tiers with different cost share ratios. Drugs on less preferable tiers result in higher out of pocket costs for members. To achieve placement on preferred formulary tiers, manufacturers negotiate rebates, based on a percentage of WAC, that are payable to PBMs as drug products are dispensed. PBMs then pass through some or all of the rebates to payers, reducing the net amount paid by the payer for the specific drug product. The difference between the rebate amount received and the rebate amount passed through is retained by the PBM as revenue.
Pricing component data reported to MHDO by PBMs shows that, on average, PBMs received rebates from manufacturers representing 17.16% of the average WAC amount (see footnote 8) for brand NDCs and 3.58% for generic NDCs (3.94% overall). While the percentage of rebates reported as passed through to payers varied significantly at an NDC level, when measured in the aggregate, 89.51% of the total amount of rebates reported by PBMs was passed through to commercial payers.
Zytiga (Abiraterone Acetate) 250 Mg 120 Count Tablets – a typical 30-day supply used for Prostate Cancer that has spread.
The MHDO continued its analysis of brand and generic WAC and AWP manufacturer pricing against amounts paid by payers and consumers for multisource drug product Zytiga (Abiraterone Acetate) 250 Mg 120 Count Tablets – the case study now represents five years of manufacturer pricing and related claims payment amounts. Zytiga is used to treat men with prostate cancer that has spread to other parts of the body. Pharmacy claims reported to MHDO for the drug totaled $32.3M during the five-year period (2019-2023). This drug has been in the Top 25 most costly generic list for the last 5 years and currently represents five of the Top 25 NDCs.
Background Information:
See the table below which details the values of WAC, AWP, and Average Payment Amounts for a 30-day course of therapy of Abiraterone Acetate 250 Mg tablets for each manufacturer price period.
Zytiga 250 Mg 120 Count Tablets – WAC & AWP Correlation to Payer Paid Amounts
During the five-year period for which MHDO prescription claims were reviewed (2019-2023):
Low Cost Generic Alternative
In July 2022, the manufacturer Civicascript introduced its generic Zytiga product to market with a WAC price of $160.00 and did not specify an AWP price. Instead, Civicascript published a Maximum Retail Price (MaxRP) policy that specified a maximum recommended price for participating pharmacies – the initial MaxRP price was set at $171.00. Between July 2022 and December 2023, payers paid an average of $204.00 for a 30-day course of therapy for the Civicascript product. While Civicascript represented the lowest cost alternative in the market for both pharmacies and payers, Civicascript has realized less than 1% of the market share in Maine since the product launched. At the same time, generic Zytiga consistently represents one of the top 25 most costly generic products across payers in Maine with five NDCs represented on the current report.
In February 2024, Civicascript further reduced the WAC for their product to $120.00 and specified a MaxRP policy value of $141.00 to be paid by payers and consumers. Additional information about Civicascript’s approach and price differentiation can be found here.
A visual correlation of average claim paid amounts to WAC and AWP values for brand and generic products is provided in the chart below.
Zytiga 250 Mg 120 Count Tablet - WAC & AWP Correlation to Payer Paid Amounts
MHDO Rule Chapter 570, Uniform Reporting System for Prescription Drug Price Data Sets
90-590, CMR Chapter 570, Uniform Reporting System for Prescription Drug Price Data Sets, defines the requirements for the registration of reporting entities; conditions under which MHDO must provide notice of substantial drug price changes or introductions; conditions under which the MHDO requires pricing component data from a reporting entity; the data elements contained in the various reports; proper coding, formatting, and submission of data; and submission deadlines.
As of November 1, 2024, 670 pharmaceutical manufacturers, 210 wholesale drug distributors and 35 pharmacy benefit managers have registered with the MHDO.
Public Notice of Substantial Drug Price Change or Introduction
Beginning January 30, 2022, MHDO is required to compile and publicly post on its website a list of all prescription drugs for which a manufacturer has during the prior calendar year:
Notifications by MHDO to Reporting Entities
Beginning February 15, 2022, and annually thereafter, MHDO must produce and post on its publicly accessible website a list of drug product families for which it intends to require reporting of pricing component data by reporting entities. In determining this list, MHDO considers the relevance of specific drug products in providing greater consumer awareness of the factors contributing to the cost of prescription drugs in the state. MHDO included 97 drug product families in the list for calendar year 2023, each having one or more NDCs that was:
MHDO Notification to Reporting Entities requesting Pricing Component Data
MHDO is responsible for identifying specific drug products of interest and notifying reporting entities that they must report pricing component data to MHDO as defined in 90-590 CMR Chapter 570, Uniform Reporting System for Prescription Drug Price Data Sets, for those drug products. Each drug product is identified by its NDC. Throughout the report, NDC is used to describe a manufacturer specific drug product.
MHDO requested pricing component data from reporting entities for 807 NDCs (which represents less than 1% of all NDCs) that are manufactured by 134 distinct manufacturers. Of these NDCS, 154 were brand drugs and 749 were generic drugs.
Data Validation,Consolidation and Analysis
Pricing component data files for CY 2023 were submitted by reporting entities to the MHDO Prescription Drug Price Data Portal in the summer of 2024. The subset of NDCs for which MHDO received pricing component data is used to highlight pricing, rebate, and brand to generic drug utilization statistics for drugs identified as having high impact to prescription drug costs in Maine. Pricing component data files are validated for completeness and accuracy. Where values fall outside of expected parameters, reporting entities are required to correct and resubmit reported data or provide explanations.
In addition to incorporating data submitted by reporting entities in this annual report, MHDO included descriptive drug product and historical pricing information compiled from Wolters Kluwer’s Medi-Span MedFile v2 data file, and retail and mail order pharmaceutical claims data submitted to the MHDO APCD as required by 90-590 Rule Chapter 243, Uniform Reporting System for Health Care Claims Data Sets. APCD claims are limited to single line, primary payor, paid claims to eliminate duplicate line claim counts and inflated paid amounts. Prescription drug claims submitted as part of a medical claim record are excluded from this analysis. Records are further constrained to claims for drug products that by federal law, can be lawfully dispensed or administered only on prescription by a licensed health care professional. The analysis excludes claims for over-the-counter drugs, medical supplies, medical devices, and diagnostic agents.
These supplemental data sets enabled review of claim volume and costs before and during the 2023 reporting period. Additionally, portions of the report use supplemental data to expand beyond NDCs reported by reporting entities to show more general trends in the overall prescription drug marketplace.
1 Medicare claims include Medicare Advantage and Medicare Part D claims. Prescription drug benefits for Medicare are provided through private plans that contract with the federal government.
2 WoltersKluwer Website. AWP Policy. Accessed February 7, 2025 at https://www.wolterskluwer.com/-/media/project/wolterskluwer/oneweb/www/health/ce/files/clinical/wkh-awp-policy.pdf
3 The pool of drugs for which pricing component data was requested is inclusive of drug families that are represented on the MHDO Dashboard of the Top 25 drugs that are the most costly, most prescribed, or which had the highest year-over-year increase in cost
4Pharmacies may also contract directly with manufacturers to procure drug products. In these cases, MHDO assumes pharmacy acquisition costs are more favorable than what is otherwise available from wholesalers, increasing pharmacy profitability. All other supply chain components remain the same.
5 Active NDCs are those NDCs that are currently available in the market.
6 Claim payments do not reflect the effect of drug rebates. 21.71% of the brand claims represented for 2023 were prescribed as Dispense As Written, indicating the medical provider determined that the branded NDC was more appropriate for the consumer and should not be filled as a generic.
7 Analysis of claims paid below acquisition costs excludes claims where the pharmacy specified a Gross Amount Due (charge amount) that was less than average acquisition costs for the drug. These claims include payment requests for drugs dispensed under the 340B program where pharmacies are provided significant discounts by manufacturers and pass through some or all of the savings to payers.
8 Rebate percentage values are calculated at the drug (NDC) level for each reporting entity as the total rebate receivable amount divided by the total number of whole NDC units sold by wholesalers or administered by PBMs (i.e., the total rebate receivable per NDC unit) divided by the average WAC amount for the NDC. Average WAC is calculated by summing the mathematical product(s) of the number of days during the year a drug product is priced at a unique WAC value multiplied by the unique WAC value and dividing the sum of all mathematical products by the number of days in the year. ((($a x 31 days) + ($b x 150 days) + ($c x 184 days)) / 365 days
9 A study published by the National Institutes of Health found that the true cost of drug acquisition at pharmacies was an average 1% lower than WAC for brand drugs and 9.8% lower than WAC for generic drugs.