Simplifying Inflation Rebate Penalties Under Medicare Part B and D

March 20, 2024 11:00am

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