NASP’s Comments on the Office of Inspector General (OIG) Department of Health and Human Services (HHS) proposed regulation, “Fraud and Abuse; Removal of Safe Harbor Protection for Rebates Involving Prescription Pharmaceuticals and Creation of New Safe Harbor Protection for Certain Point-of-Sale Reductions in Price on Prescription Pharmaceuticals and Certain Pharmacy Benefit Manager Service Fees” [84 Fed. Reg. No. 25, February 6, 2019; OIG-0936-P; RIN 0936-AA08].
NASP’s Comments on Centers for Medicare and Medicaid Services’ (CMS) proposed regulation, “Modernizing Part D and Medicare Advantage to Lower Drug Prices and Reduce Out-of-Pocket Expenses” [83 Fed. Reg. No. 231, November 30, 2018; CMS-4180-P; RIN 0938-AT92).
Medicare Program; Contract Year 2019 Policy and Technical Changes to the Medicare Advantage, Medicare Cost Plan, Medicare Fee-for-Service, the Medicare Prescription Drug Benefit Programs, and the PACE Program