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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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European and Global Private Equity Health Care and Life Sciences 2020 Review and Looking Ahead to 2021


Time to Read: 1 minutes Practices: Health Care, Europe

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The COVID-19 pandemic has transformed the business landscape across the health care and life sciences industries, and continues to do so. In this unprecedented year, Ropes & Gray has delivered the expertise and intellectual heft that our clients needed to confront the pandemic. Our health care and life sciences practice has stood out this year as being the leading legal adviser in these sectors and received multiple awards recognising that, some examples of which are set out in this newsletter.

The strength of our health care and life sciences practice, together with our market-leading private equity practice, places us in a unique position as the preeminent law firm for PE funds investing in these sectors.

Out of the London office, we acted for clients investing in, amongst other things, vaccine manufacturing sites, cancer diagnostics and treatment, pharmaceutical services, and direct-to-consumer products and sales. We believe that there is a great deal of opportunity for investors as a result of the changing landscape.

We look forward to working with you this year.

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