Wednesday, September 15, 2010

MDRP 2010 Conference - AMP after HCR: Implementation is Here – What Issues Still Remain?

Steven Benz – Eli Lilly and Company
Katie Lapins – Government Pricing Specialists

So, you spent much time and money setting up your COT based on the DRA changes we all had to implement in 2007… guess what? You have to do it again. Just as we were all getting used to the understanding of what our companies were including and excluding by how those sales were treated.

Now, the healthcare reform language may change that sale and place it into another class of trade with a change to the include/exclude methodology you have. Well, it is another process of determining how those sales are treated and where they fall in the AMP calculation. Which if you are working in Excel this is not that big of a deal as you have your historical data that is set and archived for the suggested 10 years.

But what if you have a system? Will that system think that you are changing your methodology for all historical calculations? In thinking that you are making a complete change in the methodology (because the system does not understand that congress likes to make sure we are never having a dull moment when it comes to AMP) will your system recalculate all of your historical GP information?

If your system is recalculating the numbers, you will lose the ability to go back to a past calculation in the case of a recalc or for audit purposes. If you are not sure about how your system will treat past calculations, you must be sure to make a snap-shot of your historical calculations. And ensure that you have the numbers and methodologies for those calcs and archive them as you had them when they were submitted to CMS. Remember, being able to rebuild your calculation at the time and during the correct regulation language it imperative to be compliant based on the date of the AMP submission; none of the regulations (so far) do not change what you have done in the past, only what you are going to do moving forward.

Happy Calculating!

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