At the recent Pricing and Contracting USA 2025 Conference, industry leaders came together to address the growing complexity and operational challenges of state price transparency compliance. Lynetta Moore from IntegriChain and AJ Brunovsky, Senior Manager on the Government Accountability Team at Novo Nordisk, led an in-depth discussion on recent regulatory developments, practical reporting strategies, and the future of compliance automation.
The session focused on three central themes: the current state reporting environment across key states, the value of automation and assumption modeling, and best practices for creating sustainable, audit-ready transparency programs. The insights shared reflected years of hands-on experience with emerging laws, ambiguous requirements, and evolving enforcement approaches—making it clear that collaboration, planning, and adaptability are key.
State Spotlight: Reporting Requirements and Enforcement Trends
State drug price transparency laws continue to evolve, with states like New Jersey, New York, and New Mexico leading the charge in developing complex and often inconsistent reporting requirements. Manufacturers face a growing burden of understanding not just what to report, but when, how, and with what supporting assumptions. These laws differ widely in terms of reporting triggers, submission platforms, data granularity, and public disclosure—making compliance both high-risk and high-effort.
In New Jersey, the reporting framework includes both new drug notifications and price increase reports, triggered by specific WAC thresholds and timelines. What makes the state unique is its two-part reporting structure: an initial notification due within 10 days of the market introduction or price increase, followed by a detailed report 20 days after. Importantly, the 20-day follow-up report is tied to the market introduction or effective WAC date—not the initial 10-day notice, which can lead to confusion. “Be cognizant of that,” the team emphasized, as timelines vary significantly from state to state.
New York presents its own set of challenges, particularly due to its public-facing submission process and 60-day advance notification rule. The state’s open reporting form and commitment to publishing submissions within five days create a heightened sensitivity around confidentiality and trade secret claims.
New Mexico, one of the newest players, adds further complexity with requirements based on a 30-day course of treatment and an unusual definition of WAC. Its online reporting portal is open but lacks credentialing, and each submission requires a full re-entry of organization and product data. Manufacturers are expected to provide international pricing details across up to 10 countries and respond to unique requests for generic equivalents, regardless of whether they manufacture generics. Many in the industry are still determining how to interpret these unclear requirements.
Each of these states differs in data expectations, timelines, submission platforms, and definitions. Yet a common thread is clear: enforcement is growing. While California remains the most active enforcer of penalties, Oregon, Minnesota, and Washington are stepping up. “For Oregon, as of April 1, they have given themselves the ability to enforce more of their penalties…while they are still very willing to work with manufacturers they’re looking for ways in which to enforce compliance,” shared Lynetta Moore, emphasizing the urgency for manufacturers to get ahead of compliance issues.
Automation as a Supplement – not a Replacement – for Strategic Compliance
As a reminder, the As reporting requirements grow more complex, so does the volume of data and internal coordination required to meet them. The speakers discussed how automation tools and system-based workflows are playing an increasingly important role in state transparency programs.
Rather than replacing personnel, technology is increasingly used to manage tasks such as data formatting, field population, stakeholder reminders, assumption tracking, and submission archiving. For companies with multiple products or complex reporting portfolios, automation allows compliance leads to shift their focus from repetitive data entry to strategic assumption documentation, stakeholder collaboration, and policy interpretation.
Automation also helps manage the common issue of cross-state consistency. What is submitted in one state often ends up being referenced by others—making it vital that public statements, assumptions, and trade secret claims remain consistent across jurisdictions.
Building Sustainable and Audit-Ready Compliance Programs
To ensure long-term compliance and reduce audit risk, manufacturers must develop scalable transparency programs rooted in documentation, process control, and cross-functional collaboration. A sustainable compliance infrastructure requires not just systems and tools, but also consistent operational practices, stakeholder education, and up-to-date monitoring of legislative changes across all jurisdictions.
An effective operational assessment begins with understanding whether a new law requires an entirely new process, or if current structures can be adapted. From there, manufacturers should develop robust product master files with state-specific data elements, dates, pricing, and WAC thresholds—keeping in mind that even subtle differences between state laws can change how a product must be reported.
A formal assumption log, with timestamps for when assumptions were activated or inactivated, provides a clear audit trail that can be referenced in case of state follow-ups or enforcement. Policies and procedures—especially around launch planning, data sourcing, and stakeholder involvement—should be in place and regularly reviewed.
The team also emphasized the importance of cross-functional education. “Educating your other departments and senior management is crucial,” Moore explained. This can be done through overview decks, regular cross-functional meetings, or hub-and-spoke updates tailored to finance, regulatory, and legal stakeholders.
Lastly, by working closely with public affairs teams or leveraging third-party trackers, manufacturers can identify high-priority legislation early and begin operationalizing compliance well before laws go into effect. This is particularly important in fast-moving scenarios like Colorado’s WAC disclosure requirements, which offered little lead time from enactment to enforcement.
Final Thoughts: A Shared Responsibility for Transparency Success
This session made it clear that state price transparency is no longer a side function or compliance afterthought. It’s a multi-stakeholder, enterprise-wide responsibility that demands dedicated systems, consistent documentation, and informed decision-making.
Manufacturers must continue to adapt—leveraging technology where it helps, aligning teams around shared assumptions, and staying vigilant in tracking new legislation. With the right infrastructure and collaborative mindset, compliance doesn’t have to be a burden. It can become a source of strategic readiness.
To learn more about State Price Transparency Compliance, join us at our upcoming Access Insights Conference this October and contact our Sales team for more information.
