Focus on Part D Manufacturer Discount Program

David J. Farber
Partner
King & Spalding (Washington, D.C.)

Robert J. Hill
Partner
Reed Smith LLP
- Identifying key differences with the Part D Manufacturer Discount Program and the Coverage Gap Discount Program
- Exploring the criteria for whether a claim qualifies for no discount, 10% or 20%
- Analyzing the requirements for paying lower discounts as a “specified manufacturer” or “specified small manufacturer”
- Evaluating how CMS will monitor for changes that could lead to a loss of such status
- Understanding manufacturers’ contractual obligations to CMS
- Exploring manufacturer audit rights and parameters