NPC Submits Comments to CMS on Medicaid Drug Rebate Program

In this comment letter, NPC weighs in on CMS' proposed rule changes to the Medicaid Drug Rebate Program (MDRP).

NPC's comment letter to CMS

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: 

  1. Eliminate the proposed changes to the Best Price determination
  2. Withdraw the proposal for a manufacturer drug price verification survey
  3. Remove the unnecessary and limiting proposed definition of "vaccine"
  4. Evaluate the potential administrative burden on providers of requiring diagnosis codes on Medicaid prescriptions
Read the full comment letter