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Part D/Commercial Firewalls Aid Negotiations On Donut Hole Discount Offsets

Executive Summary

Manufacturers often place firewalls between drug price negotiations for an insurer's commercial plans and Medicare Part D plans to avoid running afoul of federal anti-kickback statutes. This may have another benefit: providing latitude for Part D pricing that offsets the mandatory 50% discounts manufacturers will give on drugs used by Medicare patients in the donut hole.
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