Four Gross-to-Net Revenue Accounting Pitfalls to Avoid 

Gross-to-net (“GTN”) revenue accounting permeates life sciences, especially the sale of pharmaceutical products. Many organizations use third parties to commercialize their products by working with distributors to maximize distribution efficiencies and penetrate a large customer network. In exchange for services, distribution firms receive discounts (typically between 2% and 5% of the list price) and rebates that reduce the gross selling price realization. Other pricing adjustments, such as chargebacks, government rebates, and sales returns, impact the gross selling price. 

What is gross-to-net revenue accounting? 

GTN, the accounting for pricing adjustments, represents the difference between the gross price/wholesaler acquisition cost (“WAC”) and the net sale recognized. Pricing adjustments are a significant percentage of the WAC price and can reduce it by as much as 70%.  

What are the most prevalent GTN pricing adjustments? 

Chargebacks 

Distribution firms purchase drugs from a manufacturer at a gross price (the WAC) and sell them to consumers at a different contract price. When the consumer contract price is lower than the WAC price, the distributor minimizes losses by charging the manufacturer for the difference. 

Rebates 

These primarily relate to distribution fees paid to distributors and other service providers. The pricing adjustment can be a percentage of the selling price or a per-unit rebate (fixed dollar amount per product sold). 

Medicaid rebates 

These include discounts and rebates provided to governmental entities that are paid to the states by the manufacturer. 

Returns 

Manufacturers generally accept returns from six months before to 12 months after the products’ expiration date. 

GAAP accounting requires that the selling price to the buyer is substantially fixed and determinable at the point of sale, and the amount of future returns can be estimated to recognize revenue. Customers may not deduct pricing adjustments for months, or even years, after the product is sold.  

The new revenue recognition standard—effective for public entities beginning after December 15, 2017, and one year later for all other entities—places a significant burden on companies to estimate all pricing adjustments when the product is sold. Thus, it becomes critical to develop systems and processes that can capture these deductions in a detailed and timely fashion.  

Pricing adjustments would be accounted for as contra-sales (sales deductions) and as reductions to accounts receivable or liabilities when the product is sold. Accounting for pricing adjustments should result in a value that closely resembles the amount that companies anticipate collecting from their customers.  

Common challenges in accounting for pricing adjustments 

1. Insufficient systems and procedures to account for pricing adjustments 
   
   The amount and form of data related to pricing adjustments are substantial. With a tremendous amount of data, the pricing adjustments can be communicated via electronic transfer, paper documents, PDFs, or Excel spreadsheets. Organizations without adequate systems and processes to accumulate and process this data are disadvantaged when understanding their products and profitability.  
   
   Robust processes and systems give firms the appropriate and detailed information that can ultimately lead to better decisions regarding the viability and profitability of products, forecasting and budgeting, negotiation of the price of products with customers, and accounting for the transactions such as including the setup of appropriate accruals and processing transactions in the order-to-cash cycle. 
   
   
2. Inability to verify pricing adjustments taken by customers 
   
   Recent consolidations in the pharmaceutical industry have resulted in a greater concentration of business with distributors—increasing their negotiating power with manufacturers and resulting in lower prices and more marketplace volatility. This volatility makes it paramount that companies understand the deductions their customers take so that they can manage their portfolios.  
   
   Without the ability to accumulate pricing at the product level, manufacturers are vulnerable to not having the ability to verify and substantiate pricing adjustments taken by customers or identify market trends that directly affect product profitability.   
   
   
3. Audit compliance and financial reporting 
   
   The inability to accumulate and process data related to pricing adjustments could also result in significant true-ups in estimates of pricing adjustments, delays in the ability to recognize revenue until pricing adjustments can be determined and properly supported, and the inability to properly substantiate revenue recognition estimates.  
   
   
4. Profit-sharing arrangements 
   
   In product profit-sharing arrangements, poor accounting for pricing adjustments could result in inaccurate information provided to partners, difficulties responding to partner inquiries regarding developments in the market and pricing for specific products, and loss of partner trust regarding reporting of results and sharing of profits. 
   
   To mitigate the challenges above, you must develop an efficient model to accumulate, monitor, account for, and analyze pricing adjustment data. Firms should also develop detailed analytics to understand trends and the magnitude and appropriateness of customer pricing adjustments. The most successful companies use a combination of in-house technology (adequate ERP and general ledger systems) and third-party resources.  
   
   Firms should have adequate and clearly documented controls and procedures to validate pricing adjustments. An appropriately designed system facilitates the information needed to fully understand and analyze the market, profitability, and product trends so that you can make informed business decisions.