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.