Medicare Part D 2023 Proposed Rule Could Increase Costs

Under the current Part D structure, plan sponsors may negotiate point of sale (POS) and post-POS price concessions with pharmacies. POS price concessions, such as discounts off average wholesale price (AWP), reduce the drug cost at the pharmacy counter. Post-POS price concessions are based on metrics that cannot be reasonably determined at the POS and are reported to the Centers for Medicare and Medicaid Services (CMA) as direct and indirect remuneration (DIR).

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