As previously reported, the ACA modified the statutory FUL provisions for Medicaid reimbursement for multiple source drugs. In short, the ACA directs the Secretary to calculate FULs as no less than 175% of the weighted average (determined on the basis of utilization) of the most recently reported monthly average manufacturer prices (AMP), effective October 1, 2010. While CMS has not yet promulgated regulations to implement this policy, CMS has now issued two sets of draft FUL reimbursement files, including the draft methodology used to calculate the FULs in accordance with the ACA and the weighted average of monthly AMPs in a FUL group. The most recent draft FUL prices are based on the manufacturer reported and certified August 2011 monthly AMP and AMP unit data. The draft files are being released for review and comment only; while no comment deadline is specified, CMS has urged comments to be submitted as soon as possible to be considered in the final ACA FULs. In releasing the files, CMS notes that the ACA requires the FUL amendments to take effect whether or not implementing regulations are issued.