In this episode, Greg and Rob are joined by healthcare attorney Todd Nova to discuss a proposed rule change put forth by CMS in 2023 regarding the Medicaid Drug Rebate Program (MDRP), which includes a potential change to the definition of “covered outpatient drug”. They’ll discuss how covered entities have historically interpreted the definition of covered outpatient drugs, and what impact might come from CMS’s proposed change in this definition. Greg and Rob also get Todd’s take on recent HRSA audit activity in a post-Genesis 340B environment.

In the intro, the guys discuss the recent announcement of Medicare prices on the first 10 drugs subject to IRA-mandated drug price negotiations, a court ruling in Texas over DSH% calculation and use of Section 1115 waiver days, and changes to claims submission via 340B ESP.