CMS has posted a June 29, 2011 memo to pharmaceutical manufacturers on certain ACA Medicare Coverage Gap Discount Program issue. In brief, the memo sets forth CMS’s proposed short- and long-term solutions to a problem with providing to manufacturers “Medicare Part D Discount Information” related to certain low-volume claims while protecting beneficiary identities. It also proposes technical corrections to the deadline for appeals related to coverage gap discount agreements. CMS will accept comments on its proposals until August 1, 2011. The memo also announces that CMS intends to undertake a formal rulemaking process to codify aspects of the Discount Program, including a new definition of “Medicare Part D Discount information.” CMS expects to issue a proposed rule in the fall and a final rule in the spring of 2012.