40 of 103 GLP‑1 packages have a federal acquisition cost, priced per pen

CMS publishes NADAC as a rate per pricing unit, which for the GLP-1 injectables is a millilitre.1 Across the 30 packages priced per millilitre, that rate runs from $87.04 to $681.26 per millilitre, a 7.8 times spread. Multiply each rate by the pack size the FDA lists for that same product code2 and the spread collapses to 2.5 times: $526.54 to $1,306.72 for a package a pharmacy actually orders. A per-millilitre comparison between two GLP-1s is not a price comparison. It is a comparison of how concentrated they are.

BYETTA 5 MCG DOSE PEN INJ carries the highest per-unit rate on the file at $681.26 per ml, but that package holds only 1.2 ml, so it costs $817.52.1,2 VICTOZA 2-PAK 18 MG/3 ML PEN has a per-unit rate of $87.76, a fraction of it, across 6 ml, for $526.54 a package. The cheap-per-millilitre product is roughly 64.4% of the expensive one's package price rather than the small fraction the unit rate implies.

The FDA's National Drug Code directory lists 103 GLP-1 packages we track.2 40 of them, 38.8%, have both a NADAC rate and a readable pack size.1 The rest are dropped, not estimated. A package fails this test when CMS has surveyed no rate for it, or when the FDA's pack description cannot be parsed into a number of pricing units without guessing. The mean package cost across the ones that do resolve is $1,062.87.

CMS republishes NADAC weekly, and we hold 14 dated files of it, spanning February 2025 to October 2026.1 Take the 37 product codes that appear in at least four of them and compare each code's earliest file with its latest: 29 rose, 8 fell, and the mean change is +0.8%. Acquisition cost for these products is close to flat.

NADAC is the survey of what retail pharmacies pay to acquire a drug.1 It is not the manufacturer's list price, not a negotiated net price after rebates, and not what anyone pays at a counter. It is the closest thing to a wholesale cost in public federal data.

Names link to the page for that record where one is published.

The two files are joined on the eleven-digit National Drug Code. From CMS we take the latest NADAC rate per unit for each code, effective 21 October 2026.1 From the FDA's NDC directory we take the same code's package description and parse it into a number of pricing units: an Ozempic pen described as 3 mL is 3 units at a per-millilitre rate.2 Package cost is the product of the two.

A package with no rate, or a description we cannot parse into a unit count, is dropped. That is why 40 of 103 packages appear.

Compounded preparations have no National Drug Code, so CMS never surveys them and no federal acquisition cost exists for them.

1. A pharmacy acquisition cost is what a pharmacy pays a wholesaler. It is not a retail price, not a manufacturer list price, and not what a patient pays.
2. A package with no NADAC rate, or whose pack size cannot be parsed from the FDA listing, is excluded rather than estimated. That is why the two counts differ.
3. Compounded preparations have no National Drug Code and no NADAC rate, so they do not appear here at all.