Smoothing methodologies under HCR
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Sean Cassidy
Apr 29, 2010, 2:15:40 PM4/29/10
to The Bottom Line Forum: Best Practices for Addressing Health Care Reform in Life Sciences
Will smoothing methodologies for chargebacks and rebates deductions
remain under HCR, or will they go away? It may be too early to tell
minus official guidance, but does anyone have any opinions on this?
remain under HCR, or will they go away? It may be too early to tell
minus official guidance, but does anyone have any opinions on this?
Scott Medberry
May 4, 2010, 12:35:35 PM5/4/10
to The Bottom Line Forum: Best Practices for Addressing Health Care Reform in Life Sciences
I would think that the smoothing methodologies will continue to be a
part of CMS guidance. The reasons for their use remain, including the
stabilization of AMP values between periods and the reduction of
impact if AMP is not restated due to additional lagged data becoming
available. The case could be argued that smoothing becomes even more
important now with HCR since presumably fewer transactions will be
included AMP in the retail community pharmacy class of trade, giving
any small change in the number or value of lagged discounts a
disproportionately larger change in the calculated AMP value unless
smoothing is used. Of course, CMS might have different ideas.
part of CMS guidance. The reasons for their use remain, including the
stabilization of AMP values between periods and the reduction of
impact if AMP is not restated due to additional lagged data becoming
available. The case could be argued that smoothing becomes even more
important now with HCR since presumably fewer transactions will be
included AMP in the retail community pharmacy class of trade, giving
any small change in the number or value of lagged discounts a
disproportionately larger change in the calculated AMP value unless
smoothing is used. Of course, CMS might have different ideas.
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