The language in the proposed rule seems to raise doubt about how many manufacturers are doing their quarterly calculation. Does CMS expect all manufactures to calculate their quarterly AMP by adding all sales for the quarter and dividing that result by the total number of units in that quarter ((M1$+M2$+M3$)/(M1Units+M2Units+M3Units))? Or do they intend to have the calculation being the three monthly AMPs divided by 3 ((M1AMP+M2AMP+M3AMP)/3)? And if it is the divided by 3 calculation, does CMS recognize that the AMPs will be artificially inflated by that formula?
CA--Ramie Zomisky
This is comment on Proposed Rule
Medicaid Program: Covered Outpatient Drugs
View Comment
Related Comments
View AllPublic Submission Posted: 03/02/2012 ID: CMS-2012-0012-0004
Apr 02,2012 11:59 PM ET
Public Submission Posted: 03/14/2012 ID: CMS-2012-0012-0007
Apr 02,2012 11:59 PM ET
Public Submission Posted: 03/28/2012 ID: CMS-2012-0012-0008
Apr 02,2012 11:59 PM ET
Public Submission Posted: 03/28/2012 ID: CMS-2012-0012-0009
Apr 02,2012 11:59 PM ET
Public Submission Posted: 03/28/2012 ID: CMS-2012-0012-0010
Apr 02,2012 11:59 PM ET