The GAO has released an analysis entitled “Medicaid Outpatient Prescription Drugs: Estimated Changes to Federal Upper Limits Using the Formula under the Patient Protection and Affordable Care Act.” Drawing from 2008 data that pre-dates the ACA changes to the definition of average manufacturer price (AMP), the GAO estimates how, for selected drugs, estimated federal upper limit (FULs) using the AMP-based formula and 2008 data compare to pre-ACA FULs and to average retail pharmacy acquisition costs. In short, the GAO concludes that for most drugs reviewed, FULs based on the ACA’s formula were lower than pre-ACA FULs and higher than average retail pharmacy acquisition costs.