CMS Finalizes Guidance on Medicare Part D Manufacturer Discount Program
FDA Law Blog
DECEMBER 3, 2023
Below, we provide a high-level summary of the Final Guidance, focusing on the legal and regulatory updates from the May 2023 draft guidance. We do not address the technical and administrative details of the Discount Program here. The manufacturer will have 60 days to appeal the CMP before an administrative law judge (ALJ).
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