Removal of Drug Rebate Safe Harbor Protection The U.S. Department of Health and Human Services…
Changes for How Biosimilars are Reimbursed
Biosimilars have finally been accepted by the popular crowd. Coverage year 2019 (CY2019) is going…
Audit Engagement Letters Will Start in March
If you did not have the pleasure of being part of a Centers for Medicare…
The Achilles Heels of Part D in Program Audits: FA and CDAG Administration
This may seem like the movie “Groundhog Day,” but Formulary Administration (FA) and Coverage Determinations,…
Perhaps a Visit to the Physical Therapist Is in Order – Make Sure Your CDAG Process Is Not a Weak Spot
Coverage Determinations, Appeals, and Grievances (CDAG) remain a compliance Achilles heel for many Part D…
Lessons on the Audit Front
The regulatory scrutiny continues. The Centers for Medicare & Medicaid Services (CMS) 2016 Compliance and…