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. CMS has not yet promulgated regulations to implement this policy (although the agency sent the proposed rule to OMB for regulatory clearance in June 2011). In the meantime, CMS has issued three 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 September 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. CMS also has released some of the comments received to date on the previous draft FULs, along with the agency’s response to these comments.