Managed care units on Medicaid rebate invoices

[Sean Cassidy]

Anyone have any opinions on how soon manufacturers can expect to see
Managed Care units on Medicaid rebate invoices? Getting MCO
utilization data into rebate invoice friendly formats may be a
challenge for many states and it is possible that they might delay
billing operations for these units as a result.

[Scott Medberry]

I think almost everyone agrees that there will be a delay due to
resourcing constraints on the state Medicaid programs. A CMS rep was
at a recent NCPDP meeting and expressed the view that it was not clear
when the PBMs and the state Medicaid programs can work out the process
so that they can start including that utilization into the state
claims. How big a delay is harder to estimate. The most recent similar
occurrence was with the inclusion of HCPCS coded (J-code) utilization
in the claims resulting from the DRA. I think the J-code delay is
likely to be greater than what we will see this time around since
there is no new issue of conversion (cross-walk) to work through.

Since the effective date of this change is probably 3/22/2010, this
delay raises an interesting question regarding accruals. If you have
specific contracts with the plan sponsors for that utilization, the
path to accrual is straight forward, but if there is not a contract or
the data is co-mingled, some form of estimation might be necessary if
the dollar value is material.