The Centers for Medicare & Medicaid Services (CMS) published a final notice in the Federal Register on March 23, 2018, to amend and update for the first time since its original release in 1991 the Medicaid National Drug Rebate Agreement (NDRA). The updates incorporate legislative and regulatory changes that have been promulgated in the intervening years, such as the release of the Final AMP Rule in January 2016. Additionally, the Center for Medicaid and CHIP Services issued Release Number 108 on March 26, 2018, detailing exactly what actions participating drug manufacturers must take in light of the new agreement.
*This alert was originally posted on Arent Fox's Health Care Counsel blog. To read this alert in its entirety, please click here.