Thirty tablets of generic atorvastatin 20 mg cost a retail pharmacy about 85 cents in October 2026, going by the federal government's average acquisition cost of $0.02825 a tablet in CMS's NADAC data1. What the pharmacy is paid for filling that prescription has little to do with the 85 cents and a great deal to do with a contract it did not write.
For an insured patient, the payer sets the price. Most of the time the contract is with a pharmacy benefit manager (PBM) acting for a health plan, an employer or a Medicare drug plan. In Medicaid it may be the state itself. Three PBMs processed about 80 percent of all prescription drug claims in the US in 2023, according to a February 2026 memo from House Energy and Commerce Committee majority staff11. GxRadar's explainer on what a pharmacy benefit manager does covers the rest of their role.
That concentration is why pharmacy pay has drawn rulemaking, audits and new federal law over the past decade.
Ingredient cost plus a dispensing fee
A pharmacy claim has two main parts. The ingredient cost pays for the drug itself. The dispensing fee pays for filling the prescription and is meant to cover the pharmacist's time, overhead and supplies. The patient's copay or coinsurance is subtracted, and the payer covers the rest. The pharmacy's margin is whatever is left after paying its supplier and covering its own costs.
Federal Medicaid rules define the second part precisely. Under 42 CFR 447.5022, a professional dispensing fee is one that "pays for costs in excess of the ingredient cost of a covered outpatient drug each time a covered outpatient drug is dispensed." Commercial contracts use the same two-part structure but set both numbers privately.
How Medicaid sets the formula
State Medicaid programs that pay pharmacies directly, known as fee-for-service, follow the covered outpatient drugs rule3 published February 1, 2016 and effective April 1, 2016. It requires states to pay for most outpatient drugs based on actual acquisition cost plus a professional dispensing fee, and to consider both parts together when proposing a change to either. CMS walked states through the rule in State Health Official letter 16-0014. The payment ceiling now sits in 42 CFR 447.5125: the lower of acquisition cost plus the state's dispensing fee, or the pharmacy's usual and customary charge to the public.
Many states use NADAC, the federal survey of pharmacy invoice costs explained in how NADAC is calculated, to set that acquisition cost. Federal Upper Limits then cap aggregate spending on many generics, as covered in Medicaid and generic drug prices.
Medicaid managed care works differently. Where a state hands the pharmacy benefit to private health plans, those plans often hire PBMs, which set their own pharmacy payment terms. The Medicaid and CHIP Payment and Access Commission noted in April 2026 slides6 that the acquisition-cost payment standard limits spread pricing in fee-for-service, while the practice may be more common in managed care.
MAC lists and the seven-day rule
For generics with several makers, commercial and Medicare plans commonly pay ingredient cost using a maximum allowable cost, or MAC. Each PBM or plan keeps its own MAC list, and the lists are not public. Medicare Part D rules at 42 CFR 423.505(b)(21)7 require plans to update these pricing standards on January 1 and "not less frequently than once every 7 days thereafter," and to disclose updated prices to pharmacies in advance of their use.
A MAC can still fall below what a pharmacy paid, especially when a generic's price rises faster than the list moves (our history of the 2013 to 2015 price spikes shows how fast some generics climbed).
DIR fees and the 2024 Part D change
In Medicare Part D, a pharmacy's final payment used to be settled long after the prescription was filled. Plans and their PBMs often assessed pharmacy price concessions, commonly called DIR fees (for direct and indirect remuneration), after the sale. The price shown at the counter, which set the patient's coinsurance, could be higher than what the pharmacy was finally paid.
CMS changed that in a rule finalized April 29, 2022 and published in the Federal Register8 that May as CMS-4192-F. Its fact sheet9 says CMS redefined the negotiated price "as the baseline, or lowest possible, payment to a pharmacy, effective January 1, 2024," across every phase of the benefit. CMS said the change would lower beneficiary out-of-pocket costs and improve price transparency. For pharmacies, concessions now show up in the payment at the time of the claim rather than as a later clawback.
Spread pricing in government reports
Spread pricing happens when a PBM charges a plan more for a prescription than it pays the pharmacy and keeps the difference. How much money it moves is hard to pin down. MACPAC's April 2026 slides6 point to a lack of transparency into how often PBMs use spread pricing and how much revenue it generates, and say there is no comprehensive study of the practice in Medicaid.
Some states have published their own studies, which MACPAC says showed that the prices PBMs charged in Medicaid managed care were often higher than fee-for-service prices. The commission also noted that spread pricing is commonly used for generic drugs, that it gives PBMs an incentive to set pharmacy payments that may fall below a pharmacy's costs, and that switching to pass-through pricing may not reduce overall drug spending, because administrative fees for PBM services may be similar to what the spread brought in.
| Date | Event |
|---|---|
| February 1, 2016 | CMS publishes the covered outpatient drugs rule; Medicaid fee-for-service moves to acquisition cost plus a professional dispensing fee (effective April 1, 2016) |
| April 29, 2022 | CMS finalizes the Part D pharmacy price concession rule |
| January 1, 2024 | Part D pharmacy price concessions must be applied at the point of sale |
| February 3, 2026 | Consolidated Appropriations Act, 2026 (Public Law 119-75) signed, with PBM provisions for Medicare Part D and commercial plans |
Where federal and state law stood in late 2026
The Consolidated Appropriations Act, 202610, enacted February 3, 2026 as Public Law 119-75, added PBM rules for commercial insurance and Medicare Part D. MACPAC's summary6 lists pass-through of all rebates, PBM compensation tied to bona fide service fees, detailed reporting on rebates, pricing and fees, and a Government Accountability Office study of price-based PBM compensation in Medicare and Medicaid.
The same summary notes that the law "did not include Medicaid-specific provisions." Spread pricing in Medicaid managed care therefore remains a matter for state contracts and state law. A MACPAC chart drawn from a state-law tracker counted 16 states with laws prohibiting spread pricing, 25 with MAC list requirements and 24 prohibiting clawbacks.
A patient rarely sees any of this directly, though it can surface in a copay that bears no relation to the drug's acquisition cost; when the cash price beats the copay covers that case, and independent and chain pharmacies describes how contract terms differ by pharmacy type. The next federal report to watch is the GAO study of price-based PBM compensation in Medicare and Medicaid that the 2026 law ordered.
Sources and notes
- CMS (2026). NADAC (National Average Drug Acquisition Cost) 2026, data.medicaid.gov
data.medicaid.gov/dataset/fbb83258-11c7-47f5-8b18-5f8e79f7e704 - eCFR (2026). 42 CFR 447.502, Definitions (professional dispensing fee, actual acquisition cost)
www.ecfr.gov/current/title-42/chapter-IV/subchapter-C/part-447/subpart-I/section-447.502 - Federal Register via GovInfo (2016). Medicaid Program; Covered Outpatient Drugs, final rule (CMS-2345-FC)
www.govinfo.gov/content/pkg/FR-2016-02-01/html/2016-01274.htm - CMS (2016). State Health Official letter #16-001 on the Covered Outpatient Drugs final rule
www.medicaid.gov/federal-policy-guidance/downloads/smd16001.pdf - eCFR (2026). 42 CFR 447.512, Drugs: aggregate upper limits of payment
www.ecfr.gov/current/title-42/chapter-IV/subchapter-C/part-447/subpart-I/section-447.512 - MACPAC (2026). Pharmacy Benefit Managers and Medicaid (April 2026 commission slides)
www.macpac.gov/wp-content/uploads/2026/04/07_April-Slides_Pharmacy-Benefit-Managers-and-Me - eCFR (2026). 42 CFR 423.505, Contract provisions (Part D pricing standard updates)
www.ecfr.gov/current/title-42/chapter-IV/subchapter-B/part-423/subpart-K/section-423.505 - Federal Register via GovInfo (2022). Medicare Program; Contract Year 2023 Policy and Technical Changes to the Medicare Advantage and Medicare Prescription Drug Benefit Programs (CMS-4192-F)
www.govinfo.gov/content/pkg/FR-2022-05-09/html/2022-09375.htm - CMS (2022). Fact sheet: CY 2023 Medicare Advantage and Part D Final Rule (CMS-4192-F)
www.cms.gov/newsroom/fact-sheets/cy-2023-medicare-advantage-and-part-d-final-rule-cms-4192 - Public Law 119-75 (2026). Consolidated Appropriations Act, 2026
www.govinfo.gov/content/pkg/PLAW-119publ75/pdf/PLAW-119publ75.pdf - House Committee on Energy and Commerce, Majority Staff (2026). Memorandum for the February 11, 2026 Subcommittee on Health hearing on the prescription drug supply chain
d1dth6e84htgma.cloudfront.net/02_11_2026_HE_Hearing_Memorandum_1e207eb78d.pdf
Superscript numbers in the text link to these sources. GxRadar data (NADAC histories, recall and shortage counts) come from CMS and FDA files described on the sources page. Researched and drafted with AI assistance and checked against the sources above. Information current as of Nov 3, 2026 and may change. Spot an error? It will be corrected once confirmed.
Drug data in this article
Atorvastatin 20 mg tabletCited by
Generics fill 84.5% of Medicare Part D claims and account for 11.6% of the costHow Medicare drug price negotiation worksHow pharmacy dispensing fees workHow the 340B drug pricing program worksHow the NADAC survey picks its pharmacies, and who answersHow to appeal a drug coverage denialMedicaid prescription copays and the federal limits on themThe cheapest pills in GxRadar's 47-drug price basketWhat a pharmacy benefit manager doesWhat pharmacies paid for metformin, 2013 to 2026What pharmacies paid for simvastatin, 2013 to 2026What pharmacies paid for six generic antidepressants, 2013 to 2026What pharmacies pay for seven blood pressure generics, 2014 and 2026What the 2026 federal PBM law changes, and what states did firstWhat the FTC's study of pharmacy benefit managers foundHow NADAC is calculatedLevothyroxine and the price of a daily pillWAC, AWP, NADAC, MAC, FUL and ASP comparedWhat pharmacies pay for a month of common genericsWhy generic prices fall as competitors enterWhy the same generic costs different amounts at different pharmaciesWhy a 90-day fill often costs less than three 30-day fillsHow Medicare Part D pays for genericsHow a pill gets from the factory to the pharmacyIndependent and chain pharmacies, by the numbersPharmacy deserts, and what the closure data showNot health advice. GxRadar is for general information only. Nothing here is medical, pharmacy, legal or financial advice. Do not start, stop or change any medicine based on this site. Talk to your pharmacist or prescriber about your own situation. Laws, prices and program rules described here can change; confirm current details with the official source.