Chris Coburn, Senior Vice-President, CIS & Erika Scholl, Senior Manager, GP Consulting, CIS discuss how to prepare for the final AMP Rule now, in terms of reengagement, bona fide service fee assessments, and recalculations, so that the transition is as smooth as possible this winter. Join Chris at MDRP 2014 for his highlighted session below...
A What, When, Why and How Guide to the Complexities of Recalculations and Restatements; Complying with Guidance and Protocols and Minimizing Risks
Recalculations and restatements have become common for manufacturers, but they still pose significant compliance risks. Various events can trigger the need for a recalculation, and the resulting change or correction in methodology or data can impact the accuracy of historically reported prices, which in turn can create pricing changes that ripple across programs. When performed correctly, a recalculation/ restatement demonstrates that a manufacturer is proactively identifying and mitigating identified issues and errors within its government programs. However, when the proper procedures are not followed, this can further complicate and aggravate already problematic issues that put the manufacturer in greater risk of noncompliance. To further complicate matters, each agency has its own guidance and expectations related to recalculations that are not often officially documented. In this session, we explore the ins and outs of recalculations and offer insights on how to effectively communicate with the agencies and how to minimize your compliance and financial exposure.
Session topics include:
• Common triggers for a recalculation
• Guidance and protocols across programs and agencies
• Key financial and compliance risks
• Management response and planning
• Methodology considerations and key data components
• Known roadblocks in data and systems
• Internal and external resource needs
Chris Cobourn, Senior Vice President, Compliance Implementation Services (CIS)
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