The Wait Is Over: CMS Issues Final Rule With Comment Period Addressing Medicaid Drug Reimbursement and Rebates

February 232016The Wait is Over: CMS Issues Final Rule with Comment Period Addressing Medicaid Drug Reimbursement and Rebates

The final AMP rule will require that states pay for 340B drugs billed to fee-for-service Medicaid at actual acquisition cost or the 340B ceiling price plus a professional dispensing fee, require that states establish ways for covered entities to identify 340B drugs used for Medicaid managed care, and includes provisions that may make it easier for manufacturers to give voluntary discounts to 340B hospitals.

Will the onus fully be on the states to implement the necessary AMP rule changes? Not likely. Covered entities should begin exploring ways to ensure compliance with actual acquisition cost reporting and NDC compliance as it relates to Medicaid billing. Additionally, the potential financial impact of these changes should be assessed to understand and anticipate changes in Medicaid reimbursement as states modify their practices.

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