CA--Professional Provider Services

Document ID: CMS-2012-0012-0010
Document Type: Public Submission
Agency: Centers For Medicare & Medicaid Services
Received Date: March 14 2012, at 12:00 AM Eastern Daylight Time
Date Posted: March 28 2012, at 12:00 AM Eastern Standard Time
Comment Start Date: February 2 2012, at 12:00 AM Eastern Standard Time
Comment Due Date: April 2 2012, at 11:59 PM Eastern Standard Time
Tracking Number: 80fd731f
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This is comment on Proposed Rule

Medicaid Program: Covered Outpatient Drugs

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The Proposed Rule states that payments from insurers (as defined) are to be excluded from the AMP calculation. With many of these insurers now partnering with retail community pharmacies (example: Safeway will dispense product to Express Scripts members), is it CMS’ intention that manufacturers should back out those transactions and payments from their retail sales within their AMP calculations? If it is or still an open issue, I would request that CMS keep in mind the difficulty this may pose for manufacturers and complications this would add to their calculations.