With the 2020 bid submission deadline only about a month away, there are still uncertainties regarding the proposed rules for Part D rebates moving to point-of-sale (POS). Wakely recently released a white paper on this topic describing why these proposed changes affect Part D pricing, some potential options plans had at that time for handling rebates in the BPTs, and some of the consequences of these actions.

Since then, the Centers for Medicare & Medicaid Services (CMS) has released guidance on how plans should bid for 2020 given the uncertainty of whether these proposed rules will be finalized.


What are the proposed rules?