Posts Tagged "ACA"

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Individual Mandate Now 2-1-1 in Circuit Court; Supreme Court Will Weigh-In…

On November 14 the Supreme Court agreed to review the constitutionality of the Affordable Care Act’s individual mandate, granting petitions for writs of certiorari on four aspects of the 11th Circuit Court’s decision in Florida et al v. Dept. of

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ACA at the Supreme Court – What You Should Know

This note summarizes the events leading up to the Supreme Court’s likely review of the Affordable Care Act (ACA), and attempts to handicap the timing and outcome of the review We anticipate a verdict in or around June of 2012.

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ACO Final Rule Lowers the Bar for Forming and Operating an ACO – Not sure it really matters …

CMS today released the final rule on Accountable Care Organizations (ACOs); the rule can be found here Our review of the preliminary rule concluded ACOs, as designed, would have little effect on costs. CMS’ changes to the proposed rule are

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CMS Starts to (Kind of) Publish AMP – Why This Matters

Generic dispensing (i.e. gross) margins are far higher than branded dispensing margins throughout the drug trades (wholesalers, retailers, and PBMs). In our view this is primarily due to the traditional use of average wholesale price (AWP) as a benchmark for

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CMS Takes Concrete Steps Toward Replacing AWP

On August 4, 2011 CMS hosted a meeting to update external stakeholders on the status of the implementation and roll-out of the national actual acquisition cost (AAC) survey, the existence of which Secretary Sebelius first revealed in a letter to

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ESRX, MHS, and the PBM Bear Case

We update and summarize our PBM bear case in light of ESRX’ bid for MHS Generic dispensing margins (est. $9.01 / Rx) should fall toward brand levels (est. $5.77 / Rx) if average wholesale price (AWP) is replaced by a

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The (Unfortunate) Irrelevance of ACOs

Accountable Care Organizations (ACOs) are CMS-designed and sanctioned groups of Medicare providers that cooperate to produce greater quality of care, and savings in which member providers can share. Under the proposed rule there are few (risk-adjusted) savings available, and few

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CMS Says AMP is Coming; Acquisition Cost Data Reduce Generic Costs 37% in ‘Bama; Why Ortho Demand May Slow in the Mid to Longer-Term

CMS confirmed to us their intention to publish average manufacturer price (AMP) data to the general public; this is in addition to Secretary Sebelius’ February 2011 commitment to provide average acquisition cost (AAC) survey data to the states We analyze

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Uncertainty and Motive in Pharmacy Dispensing Mark-Ups

Recently we argued incremental (relative to brands) generic dispensing premia of roughly $5 / script ultimately will fall. This note addresses healthy criticisms of that note, particularly: 1) payors already know generic acquisition costs; and, 2) the generic dispensing premium

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October 29, 2010 – Why Generic Dispensing Margins (Eventually) Must Fall

October 29, 2010 – Why Generic Dispensing Margins (Eventually) Must Fall For both drug retail and PBM mail-order we estimate that per-Rx generic dispensing margins are $5 higher for generics than brands, and show that this premium results from: 1)

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