The Department received written comments from Gold Standard after the Department filed an amendment to implement Medicaid policy by rule in 2016. The comment stated that by listing only one nationally recognized database (Medi-Span) to define a "covered outpatient drug", the Department was favoring one particular vendor instead of using broader language to avoid the need for passing a new law whenever a new business enters the marketplace. Gold Standard then suggested either changing the Definitions section of the rule (Section R414-60-2) to include Gold Standard, or using broader language to include any nationally recognized database. The Department also received written requests after filing an amendment to the rule in 2017 to implement the federal Covered Outpatient Drug Rule. These requests came from Convenience, Value and Service (CVS) Health and the Utah Food Industry Association (UFIA). These entities wanted to confirm their understanding of fee-for-service rates in regard to Wholesale Acquisition Cost (WAC), Federal Upper Limit (FUL), and the Utah Maximum Allowable Cost (UMAC), and to verify their understanding of urban, rural, and out-of-state professional dispensing fees. UFIA also wanted to confirm whether UMAC would factor in the National Average Drug Acquisition Cost (NADAC), and wanted to know whether pharmacies would be required to submit their Average Acquisition Cost (AAC) on every claim submitted in regard to the Department's evaluation of Submitted Ingredient Cost.