Office of the Inspector General
Department of Health and Human Services
Thank you for the opportunity to provide comments on the proposed rule, Fraud and Abuse: Removal of Safe Harbor Protection for Rebates Involving Prescription Pharmaceuticals and Creation of New Safe Harbor Protection for Certain Point-of-Sale Reductions in Price on Prescription Pharmaceuticals and Certain Pharmacy Benefit Manager Service Fees.
The Council for Affordable Health Coverage (CAHC) is a broad-based alliance with a singular focus: bringing down the cost of health care for all Americans. CAHC promotes policies that lower health costs through increased competition, informed consumers and more choices. Our members include medical providers, patient groups, insurers, pharmaceutical manufacturers, pharmacy benefit managers (PBMs), and employers. To that end, because of our diverse membership and the wide implications of the proposed rule, our comments apply only to the proposed rule’s effects on value-based arrangements (VBAs) for pharmaceuticals.Download the Letter
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