Part 1 – Overview of Medicaid Rebate: The Basic Building Blocks

April 29, 2014 8:45am

Kathleen A. Peterson
Cooley LLP

John D. Shakow
King & Spalding LLP

• Understanding the rebate formulas and the Unit Rebate Amount (URA) calculation
• Average Manufacturer Price (AMP): what is it and how is it calculated?
– What is included and excluded from the calculation?
• What is Best Price and how is it calculated?
– What is included and excluded?
– Branded and generic product examples
• Key definitions applicable to both AMP and Best Price
– Bona fide service fees; bundled sales
– Customary prompt pay discounts
• Making class of trade classifi cations and why they are important
• Lagged and non-lagged concessions
• Smoothing; Bundling
• Bona fide services fees and administrative fees
• Rebate segment mechanics
• Base data AMP and the infl ation penalty
• What do invoices look like?
– ROSI and PQAS; how to validate the rebate