April 1st is just the beginning. The long awaited passage of the Final AMP Rule has ushered in a new era of compliance challenges for pricing professionals. While the Final Rule codified much of what industry expected, there are a number of grey areas still outstanding, including several new and unexpected provisions, bringing with them significant operational and implementational challenges.
Failure to accurately apply the new guidance, even where it is ambiguous, can result in number of negative consequences for industry including revenue leakage, whistleblower actions under False Claims and/or fines and penalties for noncompliance.
Given the complications inherent in pricing and especially with the new rule and the potential risk for penalties resulting from mistakes, it is essential that pricing professionals have a complete understanding of the provisions in the new rule as well as the opportunity to benchmark their practices against their industry peers.
Take just one day out of the office and attend this event led by a leading faculty of pricing experts to get practical guidance on updating pricing practices to account for the new guidance.
Topics of discussion include:
- An overview of the key elements of the Final Rule
- The “not generally dispensed” standard under 5i AMP
- The lack of supportive guidance for value based contracting and what to do as a result
- Specific areas where CMS may be vulnerable to litigation from manufacturers
- Revisions to the four-part test for “bona fide service fees” including the “no pass through” prong
- Regulations regarding the treatment of authorized generics in the calculation of AMP and best price of the branded drug
- The timing to include territories for purposes of calculations, smoothing, and rebate payments
- Overall best practices for government pricing