Medicare Part D 2020: Where, Oh Where, Should My Pharmacy Rebates Go?

As the 2020 bid season gets underway, a critical question being asked is how to handle prescription drug rebates and pharmacy price concessions – will these Direct and Indirect Remuneration (DIR) amounts be allowed to be paid to the Part D plan sponsors as in the past? Alternatively, will the proposed rules suggesting that the manufacturer drug rebates and pharmacy price concessions (collectively referred to as ‘rebates’ for the balance of this paper) instead be credited against the cost of the drug at the point of sale be finalized with a January 1, 2020 effective date? The rules may not be finalized before the June 3, 2019 due date of filing 2020 benefits and pricing. Guidance from CMS and OACT on the preferred method of handling rebates in the 2020 bids given these uncertainties has not yet been provided.

This paper will provide why this change affects the Part D pricing, some options for handling rebates in the BPTs and the consequences of the actions.

Sign up for the
Wakely Wire,

our industry newsletter.