The Centers for Medicare & Medicaid Services’ 2026 Physician Fee Schedule Final Rule expands documentation requirements for drug manufacturers reporting average sales price (ASP) and related service fees. CMS’ changes introduce new reporting burden and verification forms intended to tighten how manufacturers document and submit pricing inputs to the government. The rule represents the biggest overhaul to pricing compliance since 2006, increasing operational pressure on teams that manage ASP calculations, support documentation, and audit readiness. For biotech and pharma, it also raises the risk of reporting errors—potentially affecting reimbursement, reconciliation, and downstream disputes.