Tag Archives: CMS Proposed Rule

HEALTH REFORM: CMS Issues Proposed Rule Relating to Manufacturer Rebates and Reimbursement Amounts for Outpatient Prescription Drugs Dispensed to Medicaid Beneficiaries

This issue of Implementing Health & Insurance Reform summarizes and discusses some issues raised by the proposed rule (“Proposed Rule”) that the Centers for Medicare & Medicaid Services (“CMS”) published on February 2, 2012, to implement changes to the Medicaid Drug Rebate Program (“MDRP”) and to reimbursement limits for outpatient drugs covered by Medicaid.

In Part 1, we discuss proposals relating to the MDRP that would change the manner in which pharmaceutical manufacturers calculate Average Manufacturer Price (“AMP”) and Best Price for Medicaid-covered outpatient drugs and the manner in which rebates that manufacturers pay on prescriptions of those drugs dispensed to Medicaid beneficiaries are calculated. The topics covered include: the sales and price concessions manufacturers would include in their calculate AMP calculations, as well as those that would be excluded; the alternate methodology manufacturers would use to calculate AMP for so-called “5i” drugs not generally dispensed in retail community pharmacies; the calculation of Medicaid rebates for line extensions of other drugs; and new reporting obligations for manufacturers. CMS is accepting comments on the Proposed Rule until April 2, 2012.

See right or click here to download the full alert (PDF).

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Elizabeth Sullivan was featured in "CMS Proposed Rule Expands Multiple Procedure Payment Reductions to Professional Component…," published by RBMA

Elizabeth Sullivan was featured in “CMS Proposed Rule Expands Multiple Procedure Payment Reductions to Professional Component…,” published by RBMA

CMS Proposed Rule Expands Multiple Procedure Payment Reductions to Professional Component of Advanced Imaging Services
By: Elizabeth Sullivan

On July 1, 2011, the Centers for Medicare and Medicaid Services (“CMS”) released a proposed rule addressing modifications to physician payment policies and rates for 2012. Included in the rule is a proposal to expand the Multiple Procedure Payment Reduction policy (“MPPR”) to the professional component of certain imaging procedures. Currently, the MPPR only applies to the technical component of such imaging services.

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