Removal of Safe Harbor Protection for Rebates Involving Prescription Pharmaceuticals and Creation of...

NOF on behalf of the NBHPI has submitted comments to CMS and HHS regarding proposed rules that could impact osteoporosis patients access to testing and treatment. The following comment letter was submitted on April 8, 2019:

RE: Removal of Safe Harbor Protection for Rebates Involving Prescription Pharmaceuticals and Creation of New Safe Harbor Protection for Certain Point-of-Sale Reductions in Price on Prescription Pharmaceuticals and Certain Pharmacy Benefit Manager Service Fees

Dear Secretary Azar:

The National Osteoporosis Foundation (NOF) is pleased to submit its comments to the above referenced Proposed Rule promulgated by the Department of Health and Human Services (HHS) to remove Anti-Kickback Statute (AKS) safe harbor protection for manufacturer prescription drug rebates in connection with Medicare and Medicaid managed care organizations (MCOs), and include within the safe harbor point-of-sale price reductions and pharmacy benefit manager (PBM) service fees.

The NOF is the nation’s leading resource for patients, health care professionals and organizations seeking up-to-date, medically sound information and program materials on the causes, prevention and treatment of osteoporosis. Established in 1984 as America’s only voluntary, nonprofit health organization dedicated to reducing the widespread prevalence of osteoporosis, the foundation has grown to include a network of diverse stakeholders that support its goals to increase public awareness and knowledge, educate physicians and health care professionals, and support research activities concerning osteoporosis and bone health related areas.

Click here to read the full letter.