CMS publishes revised Inflation Reduction Act guidance, and address 340B identification by 2026

NCPA December 19, 2023

CMS published its revised guidance on the Inflation Reduction Act (IRA), both for Part D and Part B. In the Part D revised guidance, CMS stated that it continues to evaluate different options for identifying 340B units and will finalize a policy for excluding 340B units by plan year 2026. In March, NCPA submitted comments to CMS on how CMS can identify 340B units dispensed in Medicare Part D. NCPA highlighted the significant administrative burden posed to pharmacies identifying 340B units both proactively and retroactively. Instead, NCPA advised CMS to either have a third-party administrator identify 340B units for CMS, or have manufacturers report aggregate, approximate 340B units to CMS. For a fact sheet on CMS’ revised IRA guidance, click here. For CMS’ press release, click here.