Articles and Blogs

pharmacy benefit managers

Informational Bulletin from CMS Addresses Best Practices to Avoid 340B Duplicate Discounts


Posted on January 17, 2020 in Health Law News

Published by: Hall Render

On January 8, 2020, the Centers for Medicare & Medicaid Services (“CMS”) released an Informational Bulletin titled “Best Practices for Avoiding 340B Duplicate Discounts in Medicaid” (“Bulletin”). The Bulletin outlines best practices that CMS encourages state Medicaid agencies to consider to avoid the situation where a manufacturer provides both a Medicaid drug rebate and... READ MORE

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Hall Render’s This Week in Washington – April 12, 2019


Posted on April 12, 2019 in Federal Advocacy

Published by: Hall Render

Congressional Leaders Discuss Health Care Priorities Congress’ top leaders, Senate Majority Leader Mitch McConnell (R-KY) and House Speaker Nancy Pelosi (D-CA), announced they are not embracing “Medicare for All” as a priority at the American Hospital Association’s annual Washington conference. Both leaders reinforced that each chamber will pursue largely separate health care agendas in... READ MORE

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Claims Denials Start April 1: What You Should Know About CMS’s New Preclusion List


Posted on February 15, 2019 in Health Law News

Published by: Hall Render

Beginning April 1, 2019, Medicare Part C and D plans, PACE organizations and 1876 cost contract plans (“Plans”) will be required to deny payment for services rendered or prescriptions ordered by any provider on the new Centers for Medicare & Medicaid Services (“CMS”) Preclusion List. The Preclusion List, which was first made available to... READ MORE

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Discount Disruption: PBM Rebate Protection May Be Removed, New Safe Harbors Combat Increasing Drug Costs


Posted on February 1, 2019 in Health Law News

Published by: Hall Render

On January 31, 2019, the Department of Health and Human Services Office of Inspector General (“OIG”) issued a proposed rule that, if finalized, would eliminate Anti-Kickback Statute (“AKS”) safe harbor protection for prescription drug rebates paid by manufacturers to pharmacy benefit managers (“PBMs”), Medicare Part D plans and Medicaid managed care organizations (“Proposed Rule”).... READ MORE

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CMS Allows Medicare Advantage Plans to Implement Step Therapy for Part B Drugs – Will It Really Lower Drug Costs or Simply Increase Administrative Burdens?


Posted on September 19, 2018 in Health Law News

Published by: Hall Render

On August 7, 2018, the Centers for Medicare & Medicaid Services (“CMS”) issued a Memorandum (“Memorandum”) announcing a policy change to allow Medicare Advantage (“MA”) plans to implement step therapy programs for physician-administered and other Part B drugs. Step therapy is a type of prior authorization for drugs in which a health plan requires... READ MORE

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