CMS recently issued Medicaid Drug Rebate Program Release No. 176
regarding value-based purchasing ("VBP") arrangements.
Among other things, the notice responds to manufacturers'
questions regarding how VBP arrangements, which often include price
reductions and the provision of services to payers, affect a
drug's best price for Medicaid reporting and rebate purposes.
Generally speaking, "best price" is the lowest price
available from a manufacturer, including applicable discounts,
rebates, and other arrangements (e.g., services) that lower the
effective price paid for a drug. When applicable, a manufacturer
must report a drug's best price on a quarterly basis and use
the value in calculating any rebates that are due under the
Medicaid Drug Rebate Program.
In the notice, CMS stated that a VBP arrangement's impact on a
drug's best price will vary based on the structure of the VBP
arrangement. CMS also provided an email address manufacturers can
use to contact its CMCS Division of Pharmacy with questions
regarding specific VBP arrangements. CMS plans to publish
subsequent guidance with answers and lessons learned from common
questions and arrangements.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.