On June 19, 2020, the Centers for Medicare & Medicaid Services (CMS) issued a proposed rule to grant state Medicaid programs and other payers flexibility to enter value-based purchasing (VBP) arrangements with drug manufacturers. The proposed rule provides drug manufacturers with regulatory support to enter into VBPs with payers. VBP arrangements can be defined as “performance requirements” under the definition of a “bundled sale.” If a manufacturer is participating in a VBP arrangement, the drug manufacturer can report multiple best prices for a therapy—the prices tied to specific VBP arrangements— under the Medicaid Drug Rebate Program (MDRP). In . . .