On February 9, the CMS released initial program guidance addressing the inflation rebate provisions of the Inflation Reduction Act of 2022 (IRA). We covered the IRA highlights in a previous post.
In reviewing the calculations as well as the published CMS guidance, we identified some of our clients' drugs that were included in the initial 27 drugs with coinsurance adjustments. Based on our interpretation of the statute and our calculations for future liabilities, we identified an error in the CPI-U utilized in the initial CMS calculations. This error resulted in an inappropriate inflation price penalty for our clients products, and we contacted CMS on behalf of our clients. After receiving the industry feedback, CMS notified all impacted manufacturers and corrected the calculation of the coinsurance adjustment percentage for the affected NDCs.
We appreciate the responsiveness and quick action from CMS as the industry navigates changes brought on by the IRA! Woven Data will continue to provide expertise in reviewing any changes to upcoming regulations on behalf of our clients.
You can find the latest CMS guidance here.
Published on April 20, 2023 by Sergei Krupenin