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HHS Abandons Proposal to Reform Drug Manufacturer Rebate System

USA - July 17 2019 On Thursday, July 11, 2019, the White House administration reversed course on the Department of Health and Human Services’ (HHS) recent proposal to…

HHS Proposes Changes to the Discount Safe Harbor Framework to Realign Incentives and Put Downward Pressure on Drug Prices

USA - March 11 2019 On February 6, 2019, the Department of Health and Human Services (HHS) published a Proposed Rule modifying the Anti-Kickback Statute safe harbor…

Robert D. Nauman, John E. Wyand

CMS Updates the Part D Prescription Drug Benefit Manual - Chapter 13 & 14

USA - October 10 2018 Last month, CMS updated Chapters 13 and 14 from the Part D Prescription Drug Benefit Manual (PDBM). These updates affect Part D plan sponsor…

OIG Expands Protections Under the Anti-Kickback Safe Harbors and the CMP Exceptions

USA - January 23 2017 On December 7, 2016, the Department of Health and Human Services Office of the Inspector General (OIG) published a final rule (Final Rule) [1] that…

Patrick D. Cornelius, John Bunch, Adam D. Colvin, Steve Nash, Robert D. Nauman, Peter A. Pavarini, Sarah H. Stec, John E. Wyand

MACRA and Medicare Payment Reform: CMS Plans Increased Flexibility on Provider Participation

USA - September 12 2016 On Thursday, CMS announced that it intends to allow providers to "pick their pace of participation" for the first compliance year of Medicare's new…