NPC submitted comments to the Centers for Medicare & Medicaid Services (CMS) in response to the notice, “Medicaid Program; Misclassification of Drugs, Program Administration and Program Integrity Updates Under the Medicaid Drug Rebate Program (CMS-2434-P),” which includes major proposed changes to the calculation of Best Price. The comment letter offers four central recommendations:
- Eliminate the proposed changes to the Best Price determination
- Withdraw the proposal for a manufacturer drug price verification survey
- Remove the unnecessary and limiting proposed definition of "vaccine"
- Evaluate the potential administrative burden on providers of requiring diagnosis codes on Medicaid prescriptions