Tuesday, December 18, 2018

New Part D Regulation Stirs Speculation About Rebate Safe-Harbor Rule


Since mid-July, a proposed rule has been languishing at the Office of Management and Budget that could remove the safe-harbor protections that shelter the rebates drugmakers give to PBMs from penalties under the federal antikickback statute.
In the meantime, CMS on Nov. 26 released another rule that could essentially force Medicare Part D plans to pass all types of price concessions negotiated with pharmacies onto consumers at the point of sale. The introduction of the new Part D rule, which also seeks to revamp the protected classes of drugs and make other Part D changes, led to renewed speculation about the status of the administration's safe-harbor rebate rule.
Miryam Frieder, a vice president at Avalere, says the new Part D rule is not in opposition to the regulation still being reviewed, "but it kind of could be seen as complementary."
But the fact that the safe-harbor rebate rule has been stuck in the review process since July 18 "to me indicates there's a lot of discussion going on about this," says Larry Kocot, a principal at KPMG and national leader of its Center for Healthcare Regulatory Insight.
One of the major questions the administration has to grapple with is whether it actually has the authority to remove prescription-drug rebates' exemption from the federal antikickback statute, he says. In addition, the administration will have to figure out how to actually go about removing safe-harbor protections for rebates and replacing the current system with a new one.
The way the Citi analysts see it, removing the safe-harbor protection for drug rebates, in isolation, would have a muted impact. "While the market has focused on PBM-negotiated rebates as the chief driver contributing to drug price inflation, the PBM industry has moved over the last 3 years to reduce rebate retention to <5% as indicated in recent CVS [Health Corp.] and [Express Scripts Holding Co.] disclosures," they wrote in a research note.

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