Out of bounds: CMS proposed rule for AMP under Medicaid | Practical Law

Out of bounds: CMS proposed rule for AMP under Medicaid | Practical Law

This article explores some of the problematic aspects of CMS' proposals to regulate the MDRP, including its questionable exercise of delegated authority. In particular, it examines historical regulation of AMP, expansion of the Medicaid drug rebate programme, determining indirect sales to retail community pharmacies, calculating AMP for 5i drugs, Best Price, new requirements for line extensions, treatment of coupons, vouchers and co-payment assistance, new definition of wholesaler and the authorised generic rule on AMP and changes to CMS' policy on restatements of AMP and Best Price.

Out of bounds: CMS proposed rule for AMP under Medicaid

Practical Law UK Articles 8-518-2213 (Approx. 17 pages)

Out of bounds: CMS proposed rule for AMP under Medicaid

by Donna Lee Yesner, Stephen E Ruscus and Andrew D Ruskin, Morgan Lewis
Law stated as at 01 Nov 2011 • USA (National/Federal)
This article explores some of the problematic aspects of CMS' proposals to regulate the MDRP, including its questionable exercise of delegated authority. In particular, it examines historical regulation of AMP, expansion of the Medicaid drug rebate programme, determining indirect sales to retail community pharmacies, calculating AMP for 5i drugs, Best Price, new requirements for line extensions, treatment of coupons, vouchers and co-payment assistance, new definition of wholesaler and the authorised generic rule on AMP and changes to CMS' policy on restatements of AMP and Best Price.
This article is part of the PLC multi-jurisdictional guide to life sciences. For a full list of jurisdictional Q&As visit www.practicallaw.com/lifesciences-mjg.