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So before we begin, what are your thoughts on what’s going on in the industry today, Chris?
Chris: We are very much all in a “hurry up and wait” mode, especially from the pharmaceutical manufacturer perspective with continued delays of the final rule. But yet it is still really important to be as proactive as possible in your planning because when it hits, it could be significant and you really have to be in a comfortable position feeling that you‟ve planned for it.
Why is it important to conduct a company-specific impact analysis of the final rule?
Chris: At a high level, I think if you were to take a look at the question that we get increasingly from the CEO and CFO level, especially in smaller-sized companies where they are more involved, the simple question is: “What will the final rule mean to us and what will it take to implement it?”
When you look at all the variables and the proposed rule, if they all happen – and some of the significant things happen like the build-up rule, expansion of Medicaid to Puerto Rico, some of those types of things – it‟s significant. It‟s significant system changes, it‟s significant data that you‟ll need, it‟s significant materiality impact. So, how do you plan when you don't know which of those components will be in the final rule?
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