As previously reported, the ACA modified the statutory federal upper limit (FUL) provisions for Medicaid reimbursement for multiple source drugs. While CMS has not yet promulgated regulations to implement this policy, the agency has issued several 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 average manufacturer prices (AMP) in a FUL group. The most recent draft FUL prices – which are for review and comment only — are based on the manufacturer reported and certified October 2011 monthly AMP and AMP unit data. CMS also has posted a modified FUL methodology and data guide. Following a period of releasing the FULs in draft format, CMS plans to publish the final ACA FULs. No timeline has been announced for the final FULs, although CMS sent the proposed rule to the Office of Management and Budget for regulatory clearance in June 2011.