The Centers for Medicare & Medicaid Services (CMS) just released a controversial and important new report: Medicare Part D – Direct and Indirect Remuneration (DIR).
The report shows mixed consequences of DIRs in the Medicare Part D program. For example, manufacturer rebates (the biggest part of DIRs) reduce plan costs and Part D premiums. However, beneficiaries pay higher out-of-pockets costs because coinsurance amounts are based on the undiscounted, pre-rebate retail price. Meanwhile, the government is paying a growing share of drug costs due to catastrophic coverage.
The CMS report has important implications for how we think about rebates, gross-to-net discounts, plan premiums, and patients’ out-of-pocket expenses. That’s why industry reactions have ranged from outrage to defensiveness. I encourage you to read the report and think about how it lays the groundwork for changing the Medicare Part D program.
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