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What Awaits in the First Year of Medicare Drug Price Negotiations? CMS Issues Guidance and Solicits Comment on the 2026 Inflation Reduction Act Part D Negotiation Process

On March 15, 2023, the Centers for Medicare & Medicaid Services (“CMS”) issued an initial guidance memorandum (“Memorandum”) describing how it proposes to implement the Inflation Reduction Act Medicare Drug Price Negotiation Program (“Negotiation Program”) for the Initial Price Applicability Year of 2026 (the “Initial Year”). In the Memorandum, CMS provides further guidance regarding (i) how it intends to select the Medicare Part D drugs and biologics for which it will negotiate a maximum fair price (“MFP”) for the Initial Year (the “Selected Drugs”), (ii) the data and evidence that manufacturers will be required to submit that will inform CMS’s initial price proposals, (iii) the structure of the negotiation process, and (iv) implementation and enforcement of the MFP.

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CARES Act – Financial Relief Sections Applicable to Health Care Providers


Time to Read: 1 minutes Practices: Health Care

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Coronavirus Landing Site

A bipartisan agreement for the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), commonly referred to as Phase 3 of the federal government’s response to the coronavirus outbreak, was passed by the Senate on March 25, 2020. Key among its provisions are opportunities for health care providers to apply for financial relief. This chart summarizes the key financial relief sections that are applicable to health care providers, including (1) a $100 billion fund to reimburse certain providers for health care-related expenses or lost revenues; (2) an SBA 7(a) Paycheck Protection Program to provide no-fee loans to small businesses and 501(c)(3) non-profit organizations; (3) an expanded accelerated Medicare payment program (as further supplemented by CMS on March 28) to cover a broader group of providers and suppliers; and (4) a Federal Reserve lending program to provide direct loans to midsized businesses and non-profit organizations. 

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