Two of the many things that manufacturers did not see coming was the proposal on the inclusion of sales to the territories and the proposal to no longer allow “presumed inclusion” of sales as retail in the AMP calculation. With an effective date of the ACA being October 1, 2010, does CMS intend for all manufacturers to restate their AMP (and BP) calculations back to 4Q10?
CA--PPS
This is comment on Proposed Rule
Medicaid Program: Covered Outpatient Drugs
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