NASP’s Comments on the HHS ANPRM on the IPI Model for Medicare Part B Drugs
The National Association of Specialty Pharmacy (NASP) is pleased to represent the entire spectrum of the specialty pharmacy industry from the nation’s leading independent specialty pharmacies and practicing pharmacists to small and mid-size pharmacy benefit managers (PBMs), pharmaceutical and biotechnology manufacturers of specialty drugs; group purchasing organizations; wholesalers and distributors; integrated delivery systems and health plans; and technology and data management companies.
NASP has submitted the following comments on the HHS Advance Notice of Proposed Rulemaking (ANPRM) on the International Pricing Index (IPI) Model for Medicare Part B Drugs (83 Fed. Reg. No. 210, October 30, 2018; RIN 0938-AT91).