Simplifying Inflation Rebate Penalties Under Medicare Part B and D

Mary L. Hendrickson
Partner
Foley & Lardner LLP
- Understanding IRA inflation rebate requirements for Part B drugs and its relationship to ASP
- Examining the IRA inflation rebate requirement for Part D drugs and its relationship to AMP
- Analyzing the benchwork periods for evaluating inflation for both existing and new drugs
- Evaluating what utilization is and is not subject to the rebate requirements
- Working through the mechanics of precisely how the rebates are calculated
- Exploring penalties for manufacturers who do not comply with new rebate provisions
- Looking at the impact and interplay of the IRA inflation rebates on commercial sales