Tara Dwyer

Tara Dwyer

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CMS Proposes New Standards for Bona Fide Service Fees in Average Sales Price Calculations: What Plans, PBMs, and Other Recipients...

The CY 2026 Physician Fee Schedule Proposed Rule (PFS Proposed Rule) introduces significant changes to how drug manufacturers must treat Bona Fide Service Fees (BFSFs) when calculating Average Sales Price (ASP) for Medicare...more

7/31/2025  /  Centers for Medicare & Medicaid Services (CMS) , Fees , Manufacturers , Medicare , Pharmaceutical Industry , Prescription Drugs , Proposed Rules , Regulatory Requirements , Reporting Requirements

CMS Sheds Light on its Timeline for Expedited RADV Audits

Shortly following its announcement of sweeping changes to RADV audits, CMS shared industry guidance last week regarding upcoming deadlines for the submission of risk adjustment data corrections in advance of RADV sampling....more

6/6/2025  /  Audits , Centers for Medicare & Medicaid Services (CMS) , Filing Deadlines , Health Insurance , Medicare , Medicare Advantage , Medicare Advantage Organizations (MAOs) , New Guidance , Reporting Requirements

New York Establishes First Pharmacy Benefits Bureau in the Nation as Registration and Annual Reporting Deadlines for Pharmacy...

On May 11, 2022, New York Governor Kathy Hochul announced the creation of the Department of Financial Services’ Pharmacy Benefits Bureau. Governor Hochul noted that the Pharmacy Benefits Bureau is the first of its kind in the...more

5/26/2022  /  Annual Reports , Department of Financial Services , New York , Pharmacy Benefit Manager (PBM) , Reporting Requirements

CMS Completes Final Medicare Part D Reconciliation for 2016

CMS has completed the 2016 Final Part D Payment Reconciliation. Each Medicare Part D plan sponsor’s reconciliation reports will be available on October 12, 2017....more

10/12/2017  /  Centers for Medicare & Medicaid Services (CMS) , Drug Pricing , Health Plan Sponsors , Medicare Part D , Pharmacies , Prescription Drugs , Remuneration , Reporting Requirements

CMS Releases the Final Medicare Part D DIR Reporting Requirements for 2016

On Friday, June 23, 2017, CMS released the Final Medicare Part D DIR Reporting Requirements for 2016. Part D sponsors may begin submitting their DIR information on June 30, 2017 and must finish their submissions by the end of...more

6/26/2017  /  Centers for Medicare & Medicaid Services (CMS) , Comment Period , Medicare Part D , Pharmacies , Proposed Regulation , Provider Payments , Remuneration , Reporting Requirements

CMS Releases the Proposed Part D DIR Reporting Requirements for 2016

Yesterday, CMS released the Proposed Part D DIR (Direct and Indirect Remuneration) Reporting Requirements for 2016 and postponed the 2016 DIR Reporting deadline....more

5/18/2017  /  Centers for Medicare & Medicaid Services (CMS) , Comment Period , Medicare Part D , Proposed Regulation , Provider Payments , Remuneration , Reporting Requirements

Front End Changes and, Again, More DIR Columns

Since the beginning of the Medicare Part D program, CMS has introduced many reporting mechanisms for trying to understand drug pricing, price concessions, and the cost of providing services to Part D members. The tool CMS...more

10/20/2014  /  Centers for Medicare & Medicaid Services (CMS) , Health Plan Sponsors , Healthcare , Hospitals , Medicare Part D , Pharmaceutical Industry , Pharmacies , Prescription Drug Coverage , Prescription Drugs , Reporting Requirements
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