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NHC Comments on Medicare Drug Price Negotiation Program: Draft Guidance, Implementation of Sections 1191 – 1198 of the Social Security Act for Initial Price Applicability Year 2027 and Manufacturer Effectuation of the Maximum Fair Price (MFP) in 2026 and 2027

Putting Patients First Blog

Without appropriate guardrails, CMS’ broad definition of drugs eligible for negotiation may discourage these types of improvements. Off-label usage often emerges from real- world clinical practice and patient experiences, which might not be reflected in the guidelines. Active Moiety and Single Source Qualifying Drugs (Section 30.1)

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NHC Submits Comments to CMS RE CY 2026 Policy & Technical Changes to MA and Part D Proposed Rule

Putting Patients First Blog

3 ,4, 5 As such, the NHC supports CMS proposal to ensure that Part D sponsors cover AOMs for obesity with clinical criteria that is not more restrictive than the FDA labeling for each AOM. To strengthen the proposal, the NHC recommends that CMS avoid implementing rigid definitions of overweight and obese.