In Review: Last week, the Department of Consumer and Business Services (DCBS) issued an analysis of using NADAC as the basis for commercial pharmacy reimbursement would violate Oregon State Constitution under its non-delegation clause. As a result, DCBS would need to conduct rulemaking every time pharmacy reimbursement is updated under the bill as currently drafted.
Up Next: It is not clear how the workgroup will proceed with respect to NADAC.
If you have any questions, please contact Bill Head at bhead@pcmanet.org.