Lexology December 18, 2023
On December 14, 2023, the Centers for Medicare & Medicaid Services (CMS) published two “revised” guidance documents implementing the Medicare Part B and Part D inflation rebate provisions of the Inflation Reduction Act of 2022 (IRA). Although the overall structure of the implementation of the Part B and Part D inflation rebates remains the same, CMS did change some aspects of the programs in response to comments and intends to further revisit implementation through future rulemaking. By statute, CMS must implement the Part D inflation rebates through guidance through 2024. The IRA includes no such requirement as to Part B inflation rebates, but CMS indicates that it will rely on guidance to implement that program through 2024 as well. For...
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