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NHC Submits Comments on CMS Draft Guidance for IPAY 2028

Putting Patients First Blog

At the same time, the NHC recommends that CMS avoid incorporating the MFP into ASP calculations, as doing so could depress reimbursement rates across both Medicare and commercial markets, compounding access risks and straining provider viability. A first priority is clarifying how providers should submit claims for drugs subject to the MFP.