Yesterday CMS finalized the Medicaid rx rule that makes significant changes to Medicaid best price. A few thoughts: (1/5)

CMS clarifies from the proposed rule that manufacturers will be required to offer VBPs to states to be able to report "multiple best prices." A key question is if states will have the data and capacity to be able to participate if the deal is designed for commercial payers. (2/5)

As I've noted, a number of states (9 according to CMS) have supplemental rebate agreements for VBAs already. Our 50 state Medicaid drug survey found administrative requirements were the most common reason states were not implementing VBP agreements. (3/5) https://www.kff.org/report-section/how-state-medicaid-programs-are-managing-prescription-drug-costs-pharmacy-benefit-administration/

The rule does not address these concerns- CMS simply states that VBPs are optional for states & states need to assess if they have the capability to participate. CMS says they will not issue best practices on how to operationalize or evaluate VBPs. (4/5)

Implementation is delayed until January 2022- as we learned in 2020- a lot can change in a year. (5/5)