The Centers for Medicare and Medicaid Services (CMS) recently updated its portal for Average Sales Price (ASP) reporting under Medicare Part B. Data collection portals are also essential for manufacturer compliance with the Inflation Reduction Act and for price reporting under the Medicaid Drug Rebate Program. The 340B program operates yet another online data portal. In addition to these federal programs, states are also implementing data collection interfaces. For example, the Texas Vendor Drug Program recently launched its electronic certification of information (eCOI) portal. Despite the significance of these portals, only a small number of users have access and can directly evaluate compliance obligations. In this episode of Connected with Latham, Washington, D.C. partner Chris Schott and associate Danny Machado discuss the details of the various data collection portals with Lynn Buhl and Sophie Sam of Riparian, a pharmaceutical consulting company that helps manufacturers navigate government pricing regulations, reporting, strategies, and program operations. Drawing on Lynn and Sophie’s direct experience with the various reporting portals, the podcast explores the challenges posed by the various certification requirements, explains why CMS’ update to the ASP Data Collection Module marks a good time for manufacturers to review their reasonable assumptions, and explores how implementation of the Inflation Reduction Act will further transform the price reporting landscape.
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