Why OIG Did This Review. The IRA requires CMS to calculate inflation -indexed rebates for certain Part B drugs beginning in 2023. Prior OIG work estimated that Medicare could collect billions of dollars in inflation -indexed rebates similar to those authorized by the IRA. OIG faced several methodological challenges when conducting this past work that could be informative for CMS and stakeholders as the agency implements the new rebate provisions. This technical assistance brief is intended as technical assistance for CMS to consider as it implements these new provisions. How OIG Did This Review. This technical assistance brief compiles insights on potential challenges in implementing inflation - indexed rebates for Part B drugs. The insights provided are drawn from OIG ’s prior evaluations of Part B drug rebates and our larger body of prescription drug work. Challenges That OIG Identified. On the basis of our prior oversight work, we anticipate that unless CMS takes action to remedy several administrative issues, the agency will face the following challenges in implementing rebates: (1) Identifying products subject to Part B rebates; and (2) Excluding claims from Part B rebate calculations that were already subject to: (a) Rebates under the Medicaid Drug Rebate Program, and (b) Discounts under the 340B Drug Discount Program. We propose potential solutions to mitigate each administrative issue.
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