Medicare Part D

AMCP Submits Comments to CMS on Advance Notice of Methodological Changes for Calendar Year (CY) 2020 for Medicare Advantage (MA) Capitation Rates, Part C and Part D Payment Policies and 2020 Call Letter

On March 1, 2019, AMCP provided comments to CMS in response to its 2020 for Medicare Part D Call Letter. AMCP offered comments on the following sections of the notice; Part D Benefit Parameters for Non-Defined Standard Plans; Formulary Submissions; Medication Therapy Management (MTM); and Part D Mail Order Auto-Ship Modifications.
Legislation & Regulation, Medicare Part D, Medication Therapy Management (MTM)

AMCP Summary: Fraud and Abuse; Removal of Safe Harbor Protection for Rebates Involving Prescription Pharmaceuticals and Creation of New Safe Harbor Protection for Certain POS Reductions in Price on Prescription Pharmaceuticals

On January 31, 2019, HHS proposed sweeping changes to the current system for medication pricing and contracting by PBM companies in federal programs. This summary reviews OIG's proposal to eliminate the safe harbor protections for rebates that exist in the federal Anti-Kickback Statute (AKS) and replace these protections with proposed new safe harbors allowing for point-of-sale discounts to beneficiaries and for manufacturer-paid service fees to PBMs.
Medicaid Managed Care, Medicare Part D, Rebates, Legislation & Regulation

AMCP Submits Comments to CMS on Medicare and Medicaid Programs; Regulation to Require Drug Pricing Transparency

On January 25, 2019, AMCP provided comments to CMS in response to its proposed rule on lowering drug prices and reducing out-of-pocket expenses in the Medicare program. The letter outlines the proposal’s impact on providing plan flexibility to manage protected classes, prohibition against gag clauses in pharmacy contracts, E-Prescribing and the Part D Prescription Drug Program, Part D explanation of benefits, and Medicare Advantage and step therapy in Part B.
Legislation & Regulation, Fraud, Waste and Abuse, Medicare, Price Transparency, Medicaid, Medicare Part D