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49 terms our issues use, in plain English, each with why it matters. Healthcare hides its stakes behind initials. This is where we spell them out.

# 340B 340B Drug Pricing Program program

A federal program that requires drugmakers to sell outpatient drugs at steep discounts to hospitals and clinics that serve large numbers of low-income patients, known as covered entities. The discounts can run 25 to 50 percent or more off list price. Hospitals keep the spread between the discounted price they pay and what insurers reimburse, and are meant to plow it back into patient care. The program is named for its section of the Public Health Service Act.

Why it matters. 340B moves billions of dollars a year and is a constant fight among hospitals, drugmakers, and regulators, including CMS proposals to cut 340B payment rates and drugmaker efforts to attach new data-reporting conditions to the discounts.

See also: Covered entity, Contract pharmacy, OPPS, WAC

# ACA Affordable Care Act regulation

The 2010 health law, sometimes called Obamacare, that reshaped US health coverage. It created the insurance marketplaces, expanded Medicaid to most low-income adults, barred insurers from denying coverage for pre-existing conditions, and set minimum standards for what plans must cover. Many current fights, including Medicaid expansion and work requirements, trace back to it.

Why it matters. The ACA defines who is eligible for Medicaid expansion, the group most affected by new work requirements, and sets the rules insurers still operate under today.

See also: Medicaid work requirements, MLR

# ACO Accountable Care Organization program

A group of doctors, hospitals, and other providers that agree to jointly manage the care and total cost of a defined set of patients. If they keep spending below a target while hitting quality marks, they share in the savings; in some models they also owe money back if costs run high. ACOs are a core tool CMS uses to move Medicare away from paying for volume.

Why it matters. ACOs are how Medicare tries to reward keeping patients healthy rather than simply paying for every service, and they are a major testing ground for the CMS Innovation Center.

See also: CMS, CMMI, FFS

# ADC Antibody-Drug Conjugate clinical

A class of cancer drug that links a targeting antibody to a toxic payload, so the drug delivers its cell-killing agent directly to tumor cells while sparing healthy tissue. ADCs are one of the hottest areas of oncology drug development, drawing multibillion-dollar acquisitions of the biotech companies that build them.

Why it matters. ADCs drive large pharma deals, such as Novartis paying up to 1.5 billion dollars for a UK biotech's ADC pipeline, and represent where much cancer-drug investment is flowing.

See also: FDA, Biosimilar

# AEP Annual Election Period program

The yearly window, running October 15 to December 7, when Medicare beneficiaries can join, switch, or drop a Medicare Advantage or Part D plan for the coming year. Plan star ratings, benefits, and premiums published ahead of this window shape where seniors take their business.

Why it matters. The AEP is when Medicare Advantage and Part D plans win or lose members, which is why star ratings and quality bonus payments carry such high financial stakes.

See also: MA (Medicare Advantage), Part D, Star ratings, CY

# ASC Ambulatory Surgical Center payment

A freestanding facility where patients get surgery and procedures that do not require an overnight hospital stay. Medicare pays ASCs under a separate, generally lower rate schedule than hospital outpatient departments, and CMS updates both in the same annual rule. Steering procedures to ASCs is one way payers try to cut costs.

Why it matters. ASC payment rates are set alongside hospital outpatient rates in the OPPS rule, so the same annual regulation shapes where procedures get done and how much Medicare pays.

See also: OPPS, CMS, Prior authorization

# Biosimilar market

A near-copy of an expensive biologic drug, the large-molecule medicines grown in living cells rather than mixed chemically. Because biologics cannot be copied exactly the way a generic pill is, biosimilars must clear their own FDA review showing no meaningful clinical difference from the original. They typically enter at a lower price and pull down spending once the original loses exclusivity.

Why it matters. Biosimilars are a main lever for lowering drug costs, and licensing deals for biosimilar candidates are a recurring feature of healthcare dealmaking.

See also: FDA, ADC, WAC

# CMMI Center for Medicare and Medicaid Innovation agency

The arm of CMS, also called the Innovation Center, that designs and tests new ways to pay for and deliver care, from accountable care models to drug-pricing demonstrations. It can launch time-limited pilots without new legislation and, if a model saves money and preserves quality, expand it. Recent tests include the ACCESS Model, the Cell and Gene Therapy Access Model, and the Medicare GLP-1 Bridge.

Why it matters. The Innovation Center is where much of the experimentation in Medicare and Medicaid payment happens, so its models preview where the broader programs may head.

See also: CMS, ACO, GLP-1

# CMS Centers for Medicare and Medicaid Services agency

The federal agency, part of HHS, that runs Medicare and Medicaid and oversees the ACA marketplaces. It sets payment rates, writes coverage rules, audits health plans and providers, and can suspend or revoke billing privileges. As the largest single payer for US health care, its rulemaking moves the entire industry.

Why it matters. Nearly every payment change, audit, and coverage decision in the newsletter runs through CMS, making it the most consequential regulator a healthcare reader tracks.

See also: HHS, CMMI, MA (Medicare Advantage), RADV

# Contract pharmacy market

An outside retail pharmacy that a 340B hospital or clinic hires to dispense discounted 340B drugs on its behalf, since many covered entities lack their own pharmacy. Drugmakers have tried to cap how many contract pharmacies a covered entity can use, and several states have passed laws barring those caps. Those laws are now being fought in court.

Why it matters. Contract pharmacy access determines how far 340B discounts actually reach, and court rulings upholding state protections shape a fight playing out in roughly 20 states.

See also: 340B, Covered entity, PBM

# Covered entity program

A hospital or clinic that qualifies to buy drugs at 340B discount prices, such as disproportionate share hospitals, community health centers, and certain specialty clinics. To keep eligibility, covered entities must serve enough low-income or underserved patients and follow program rules on how discounted drugs are used. The term also appears in health privacy law, but in drug-pricing context it means a 340B participant.

Why it matters. Whether an organization counts as a covered entity decides its access to deep drug discounts, a major source of hospital revenue now under pressure from drugmakers and CMS.

See also: 340B, Contract pharmacy, DSH

# CY Calendar Year payment

The January-to-December year CMS uses to label many of its payment rules, as in the CY 2027 outpatient rule. It contrasts with the federal fiscal year, which runs October through September and governs other Medicare payment systems such as those for inpatient hospitals. Knowing which clock a rule runs on tells you when new rates take effect.

Why it matters. Payment rules are named and timed by CY or fiscal year, so the label signals exactly when a rate change hits providers.

See also: OPPS, HH PPS, ASC

# DEA Drug Enforcement Administration agency

The federal law-enforcement agency, part of the Justice Department, that regulates controlled substances, from prescription opioids and stimulants to Schedule I drugs. It registers the practitioners and pharmacies allowed to prescribe and dispense these drugs and sets the rules for doing so, including whether they can be prescribed by telehealth.

Why it matters. DEA rules decide whether patients can get controlled medications like ADHD stimulants or addiction treatment remotely, and its telehealth extensions carry hard deadlines.

See also: DOJ, SAMHSA, FDA

# DOJ Department of Justice agency

The federal department that prosecutes health care fraud, often alongside the HHS Office of Inspector General. It brings the criminal and civil cases behind fraud takedowns, provider prison sentences, and False Claims Act recoveries, and houses the DEA. Its annual health care fraud takedowns can span hundreds of defendants and billions of dollars.

Why it matters. DOJ prosecutions set the enforcement tone for the whole industry, and its takedowns can trigger payment holds and program integrity letters for providers connected to those charged.

See also: OIG, DEA, MFCU

# DSH Disproportionate Share Hospital payment

A hospital that treats a large share of low-income patients and therefore gets extra Medicare and Medicaid payments to offset uncompensated care. DSH status also helps qualify a hospital for the 340B drug discount program. Federal DSH payments run into the billions and are a recurring budget target.

Why it matters. DSH status is both a funding stream and a gateway to 340B discounts, so changes to it ripple through safety-net hospital finances.

See also: Covered entity, 340B, CMS

# FDA Food and Drug Administration agency

The federal agency that decides whether drugs, biologics, and medical devices are safe and effective enough to sell in the US. It can grant full approval, accelerated approval based on early evidence with confirmatory trials required later, and supplemental approvals that expand an existing drug to new patients. It also oversees food safety and outbreak investigations.

Why it matters. FDA approvals open or expand markets worth billions, as with new gene therapies and kidney-disease drugs, and its food investigations drive recalls.

See also: DEA, ADC, IgA nephropathy, Biosimilar

# FFS Fee-for-Service payment

The traditional way of paying for care, where a provider bills separately for each visit, test, or procedure. In Medicare, fee-for-service is Original Medicare, the government-run alternative to privately run Medicare Advantage. Critics say paying per service rewards volume over outcomes, which is why programs like ACOs try to move away from it.

Why it matters. Fee-for-service versus managed and value-based payment is the central tension in US health policy, shaping everything from ACO design to Medicaid state-directed payments.

See also: ACO, MA (Medicare Advantage), SDP

# FTC Federal Trade Commission agency

The federal agency that polices unfair competition and deceptive business practices, including in health care. It has pursued pharmacy benefit managers over drug-rebate practices tied to insulin prices, challenged hospital and pharma mergers, and brought deceptive-claims cases against health-related groups. Its actions often end in settlements that change industry conduct.

Why it matters. The FTC is the main federal check on PBM and drug-pricing practices, and its settlements can reshape how middlemen are paid.

See also: PBM, DOJ, WAC

# GAO Government Accountability Office agency

The nonpartisan watchdog arm of Congress that investigates how federal money is spent and reports back to lawmakers. Its healthcare reports, often requested by members of Congress, document gaps and waste in Medicare and Medicaid and frequently set up the next legislative push. GAO recommends but does not itself write rules.

Why it matters. GAO findings, such as a report on billions in assisted-living spending and Medicaid's room-and-board gap, often become the evidence base for new legislation.

See also: OIG, LTC, SNF

# GLP-1 Glucagon-Like Peptide-1 receptor agonist clinical

A class of drugs, including Wegovy and Zepbound, first used for diabetes and now widely prescribed for weight loss. They mimic a gut hormone that curbs appetite and blood sugar, and their high cost and huge demand strain both commercial and government drug budgets. Medicare has historically not covered them for weight loss alone.

Why it matters. GLP-1 drugs are among the biggest cost pressures in health care, prompting special Medicare and Medicaid coverage demonstrations to manage the spending.

See also: CMMI, Part D, WAC

# HCC Hierarchical Condition Category payment

The coding system Medicare uses to group patient diagnoses into categories that predict future medical costs. Each category carries a weight, and a patient's combined weights feed the risk score that sets how much a Medicare Advantage plan gets paid. Because sicker patients bring higher payments, HCC coding is a frequent target of upcoding scrutiny and audits.

Why it matters. HCC coding directly determines Medicare Advantage payments, making it the mechanism behind both risk adjustment and the audits that claw back unsupported diagnoses.

See also: RAF, Risk adjustment, RADV, MA (Medicare Advantage)

# HH PPS Home Health Prospective Payment System payment

The Medicare payment system for home health agencies, which pays a set amount per patient over a defined period rather than per visit. CMS updates it each year with a rate change, case-mix adjustments that account for how sick patients are, and sometimes a behavior adjustment that corrects for how agencies code under the rules. Comment periods on the annual rule give the industry a chance to push back.

Why it matters. The annual HH PPS rule sets the revenue home health agencies live on, and its behavior adjustments are a recurring source of industry conflict with CMS.

See also: CMS, OPPS, CY, NPRM

# HHS Department of Health and Human Services agency

The cabinet department that oversees most federal health programs and agencies, including CMS, the FDA, the Office of Inspector General, and SAMHSA. It sets broad health policy, controls major funding decisions, and its inspector general polices fraud across Medicare and Medicaid. When a rule or enforcement action is federal and health-related, HHS usually sits above it.

Why it matters. HHS is the parent agency for the regulators a healthcare reader tracks daily, so its priorities steer the whole federal health apparatus.

See also: CMS, OIG, FDA, SAMHSA

# IDD Intellectual and Developmental Disabilities clinical

A category of lifelong conditions, present from childhood, that affect learning, reasoning, or physical and social development. People with IDD often rely on Medicaid home and community-based waivers for daily support services, and demand for those services routinely outstrips the available slots. Long waitlists are common.

Why it matters. IDD services are a major Medicaid commitment, and moves to managed care or waiver expansions directly affect tens of thousands of people, many stuck years on waitlists.

See also: LTC, CMS

# IFR Interim Final Rule regulation

A regulation that takes legal effect immediately, before the public gets to comment, with comments collected afterward. Agencies use it when they claim urgency or specific legal authority, skipping the usual propose-then-finalize sequence. Because it shortcuts normal notice-and-comment, an IFR is a frequent target of lawsuits arguing the agency overstepped.

Why it matters. An interim final rule can change policy fast and is often challenged in court, as with the Medicaid work-requirement rule that took effect while more than 25 states sued over it.

See also: NPRM, Medicaid work requirements, CMS

# IgA nephropathy Immunoglobulin A nephropathy clinical

A common kidney disease, also called Berger's disease, in which deposits of the antibody IgA build up in the kidneys and cause inflammation that leaks protein into the urine. It progresses slowly but leads to kidney failure in a large share of patients over 10 to 20 years. A wave of new drugs is now competing to slow it.

Why it matters. IgA nephropathy has become a competitive drug market, with new FDA approvals like the first BAFF/APRIL dual inhibitor reshaping treatment for a disease that can end in kidney failure.

See also: FDA, ADC

# IRA Inflation Reduction Act regulation

The 2022 law that, among other things, gave Medicare the power to negotiate prices on some high-cost drugs, capped insulin costs and out-of-pocket spending for Medicare drug benefits, and required drugmakers to pay rebates when prices rise faster than inflation. It marks the biggest change to Medicare drug pricing in years and is still being phased in.

Why it matters. The IRA reshaped how Medicare pays for drugs and set the framework for ongoing fights over drug prices, rebates, and the Part D benefit.

See also: Part D, WAC, CMS

# LTC Long-Term Care market

Ongoing help with daily living for people who cannot fully care for themselves, delivered in nursing homes, assisted-living facilities, or at home. Medicare generally does not pay for extended long-term care, so Medicaid is the largest payer, though it is barred by statute from covering the room and board portion of assisted living. Costs are a growing strain on state budgets.

Why it matters. Long-term care is a huge and rising Medicaid cost that drives state budget fights and federal reports on coverage gaps, especially around assisted living and nursing homes.

See also: SNF, IDD, GAO

# MA (Medicare Advantage) Medicare Advantage program

The privately run alternative to Original Medicare, in which insurers such as Humana and UnitedHealthcare are paid a fixed amount per enrollee to cover their care. Payments are adjusted upward for sicker patients through risk scores, and plans earn bonuses for high star ratings. More than half of Medicare beneficiaries are now in MA plans.

Why it matters. Medicare Advantage is where the largest insurers compete, where risk-adjustment and audit fights play out, and where annual rate announcements move billions of dollars.

See also: Part D, Star ratings, Risk adjustment, RADV, Quality bonus payments

# MAT Medication-Assisted Treatment clinical

The use of medications such as buprenorphine, methadone, or naltrexone, combined with counseling, to treat opioid use disorder. It is the standard evidence-based approach for addiction, and federal grant dollars and telehealth prescribing rules heavily shape access to it. SAMHSA funds much of the treatment infrastructure.

Why it matters. MAT access depends on federal grants and DEA telehealth rules, so behavioral health funding and controlled-substance policy directly affect whether patients can get treatment.

See also: SAMHSA, DEA

# MCR Medical Cost Ratio payment

The share of the premium dollars an insurer collects that it pays out for members' medical care, rather than keeping for administration and profit. A ratio of 85 percent means 85 cents of every premium dollar went to care. Investors watch it closely as a sign of whether an insurer's medical costs are running hot, and it is closely related to the regulatory medical loss ratio.

Why it matters. The medical cost ratio is the single number investors and executives use to judge a health insurer's financial health, and rising ratios signal margin pressure on companies like Humana and UnitedHealth.

See also: MLR, MA (Medicare Advantage)

# Medicaid work requirements regulation

Rules that condition Medicaid coverage for many expansion adults on documenting a set number of hours, commonly 80 a month, of work, school, or community engagement. A federal interim final rule requires all states to adopt some version by January 1, 2027, and also narrows who can claim a medically frail exemption. More than two dozen states are suing to block it, while Montana and Arkansas were the first to begin.

Why it matters. Work requirements are among the most contested Medicaid changes, with the potential to strip coverage from people with conditions like cancer or HIV who cannot meet the hours.

See also: IFR, ACA, CMS

# MFCU Medicaid Fraud Control Unit agency

A state-level investigative and prosecuting unit, funded mostly by the federal government, that pursues Medicaid provider fraud and patient abuse in facilities. There is one in nearly every state, and the HHS Office of Inspector General certifies them and can pull their funding for weak performance. Losing certification is rare and severe.

Why it matters. MFCUs are the front line of Medicaid fraud enforcement, and a decertification, as happened to New York's unit over 60 million dollars in funding, signals major program-integrity failures.

See also: OIG, DOJ

# MLR Medical Loss Ratio regulation

A rule under the ACA that requires health insurers to spend a minimum share of premium dollars, generally 80 or 85 percent, on medical care and quality improvement rather than administration and profit. Insurers that fall short must rebate the difference to customers. It is the regulatory cousin of the medical cost ratio insurers track internally.

Why it matters. The MLR floor caps how much insurers can keep from premiums and can force rebates, making it a check on insurer profitability written into federal law.

See also: MCR, ACA, MA (Medicare Advantage)

# NPRM Notice of Proposed Rulemaking regulation

The formal proposal an agency publishes in the Federal Register when it wants to create or change a rule, opening a public comment period before anything is final. The public, industry, and states file comments, and the agency must consider them before issuing a final rule. Most major CMS payment changes start as an NPRM, often called a proposed rule.

Why it matters. The proposed rule stage is when the industry can still influence a policy, so comment deadlines on NPRMs are critical dates for hospitals, plans, and providers.

See also: IFR, OPPS, HH PPS, SDP

# OIG Office of Inspector General agency

The independent watchdog inside HHS that audits, investigates, and enforces against fraud, waste, and abuse in federal health programs. It maintains the exclusion list that bars bad actors from billing Medicare and Medicaid, certifies state Medicaid Fraud Control Units, and partners with the Justice Department on major fraud cases. Its reports and enforcement actions carry real financial teeth.

Why it matters. The HHS-OIG is the central fraud enforcer across Medicare and Medicaid, and its actions, from provider sentencings to defunding a state fraud unit, set enforcement priorities.

See also: DOJ, MFCU, HHS

# OPPS Outpatient Prospective Payment System payment

The Medicare payment system for services delivered in hospital outpatient departments, such as same-day procedures, imaging, and drugs given in a clinic. CMS updates the rates every calendar year in a single rule that also covers ambulatory surgical centers, and that rule is where fights over 340B drug payments and site-of-service pricing play out. Changes are budget-neutral, so cutting one payment often raises another.

Why it matters. The annual OPPS rule sets how much Medicare pays hospitals for outpatient care and is the vehicle for major policy shifts like 340B payment cuts and moving imaging to lower rates.

See also: ASC, 340B, CY, NPRM

# Part D Medicare Part D program

The Medicare prescription drug benefit, delivered through private plans that Medicare subsidizes. It has its own deductible, out-of-pocket structure, and rules for which drugs are covered, and it is where recent drug-pricing reforms, from insulin caps to negotiated prices, take effect. Low-income enrollees get extra subsidies within it.

Why it matters. Part D is the framework for how tens of millions of seniors get and pay for drugs, and special programs like the GLP-1 Bridge are built around its benefit structure.

See also: MA (Medicare Advantage), IRA, GLP-1, AEP

# PBM Pharmacy Benefit Manager market

A middleman hired by insurers and employers to manage drug benefits, deciding which drugs are covered, negotiating rebates with manufacturers, and setting what pharmacies get paid. The three largest, CVS Caremark, Express Scripts, and Optum Rx, control most of the market and are owned by or tied to big insurers. Critics say they inflate list prices and squeeze independent pharmacies.

Why it matters. PBMs sit at the center of drug-pricing fights, facing FTC settlements over insulin, state licensing crackdowns, and antitrust suits from independent pharmacies.

See also: FTC, WAC, Contract pharmacy

# Prior authorization regulation

A requirement that a provider get a payer's approval before delivering certain services or drugs, or the payer will not cover them. Insurers and Medicare use it to control costs and steer utilization, while providers complain it delays care and buries them in paperwork. CMS periodically adds or removes specific codes from prior authorization lists.

Why it matters. Prior authorization decides whether expensive procedures and drugs get paid for, and additions to Medicare's prior-authorization lists directly affect provider revenue and patient access.

See also: OPPS, ASC, CMS

# Quality bonus payments payment

Extra money Medicare pays Medicare Advantage plans that earn high star ratings, typically 4 stars or more out of 5. The bonuses can add up to hundreds of millions of dollars per insurer and must largely be passed through as richer benefits to members. Because so much money rides on the rating, plans fight hard, sometimes in court, over how CMS calculates it.

Why it matters. Quality bonus payments tie billions in insurer revenue to star ratings, which is why disputes like Elevance's lawsuit over a 115 million dollar swing end up in federal court.

See also: Star ratings, MA (Medicare Advantage), AEP

# RADV Risk Adjustment Data Validation regulation

The audit CMS uses to check whether the diagnoses a Medicare Advantage plan reported, which drive its payments, are actually supported by patients' medical records. Unsupported diagnoses mean the plan was overpaid and must return money. A key fight is over extrapolation, whether CMS can take error rates from a small sample and apply them across a plan's whole population, which sharply raises the dollars at stake.

Why it matters. RADV audits are how the government claws back Medicare Advantage overpayments, and the court fight over extrapolation could mean the difference between modest and plan-wide repayments.

See also: Risk adjustment, HCC, RAF, MA (Medicare Advantage)

# RAF Risk Adjustment Factor payment

A single score that sums up how costly a patient is expected to be, built from their diagnoses, age, and other factors. A RAF of 1.0 represents an average beneficiary; higher scores mean Medicare pays a Medicare Advantage plan more to cover that person. Because higher scores mean higher pay, RAF is where incentives to code aggressively, sometimes called upcoding, concentrate.

Why it matters. The RAF score is the number that converts a patient's diagnoses into dollars for a Medicare Advantage plan, making it the focus of both risk adjustment and audit scrutiny.

See also: HCC, Risk adjustment, RADV, MA (Medicare Advantage)

# Risk adjustment payment

The method Medicare and other payers use to pay more for sicker patients and less for healthier ones, so plans are not punished for enrolling people who need expensive care. It works by translating patient diagnoses into condition categories and a risk score that scales payment. CMS periodically updates the underlying model, and each version change shifts billions in payments.

Why it matters. Risk adjustment is the engine behind Medicare Advantage payments, and both the model updates and the audits that police it move enormous sums.

See also: HCC, RAF, RADV, MA (Medicare Advantage)

# SAMHSA Substance Abuse and Mental Health Services Administration agency

The HHS agency that leads federal efforts on mental health and substance use, mainly by distributing grants to states, tribes, counties, schools, and community providers. It funds opioid treatment, school mental health programs, overdose-reversal training, and crisis services. Its grant announcements set much of the behavioral health funding landscape.

Why it matters. SAMHSA grants are a primary source of money for addiction and mental health treatment, so its funding rounds, sometimes hundreds of millions of dollars, shape access on the ground.

See also: MAT, HHS, DEA

# SDP State-Directed Payments payment

Arrangements that let states require their Medicaid managed-care plans to pay providers, often hospitals, at set rates above the base, funneling extra federal dollars into the system. They have become a fast-growing and contested part of Medicaid financing. CMS is tightening the rules, including requiring states to file their payment plans before the money moves and limiting who can receive it.

Why it matters. State-directed payments are a major and growing channel of Medicaid money for hospitals, and CMS restrictions on filing timing and intermediaries directly hit that revenue.

See also: FFS, CMS, NPRM, DSH

# SNF Skilled Nursing Facility market

A facility, commonly called a nursing home, that provides round-the-clock skilled nursing and rehabilitation, usually for older adults recovering from a hospital stay or needing ongoing care. Medicare covers short post-hospital stays, while Medicaid is the main payer for long stays. Occupancy, real estate deals, and REIT ownership make SNFs a closely watched investment sector.

Why it matters. Skilled nursing facilities are a major healthcare real estate and Medicaid spending category, and portfolio sales and occupancy trends signal the sector's financial health.

See also: LTC, GAO, IDD

# Star ratings program

The 1-to-5-star scores CMS assigns each Medicare Advantage and Part D plan based on dozens of quality, outcome, and customer-experience measures. Higher-rated plans earn bonus payments and can enroll members year-round, while consistently low ratings can push a plan out of the program. Plans dispute the exact measures and math, sometimes in court, because a fraction of a star can mean tens of millions of dollars.

Why it matters. Star ratings drive both quality bonus payments and enrollment, so the methodology behind them is a high-stakes battleground for insurers.

See also: Quality bonus payments, MA (Medicare Advantage), AEP

# WAC Wholesale Acquisition Cost market

A drug's list price to wholesalers, set by the manufacturer before any rebates or discounts. It is the sticker price that anchors much of the drug supply chain, including 340B discounts calculated off of it, even though few buyers pay the full WAC. Changes to WAC ripple through what hospitals, pharmacies, and patients ultimately owe.

Why it matters. WAC is the baseline drug price everything else is negotiated against, so a manufacturer raising it, as with a 340B drug jumping 35.9 percent, directly hits hospital and patient costs.

See also: 340B, PBM, IRA, Biosimilar