Paragon Solutions’ recently published the whitepaper, “Key Considerations for Effective Processing of the Coverage Gap Discount Program (CGDP)”, which provides details on the essentials that manufacturers need to consider and implement to support efficient processing of the Coverage Gap Discount Program (CGDP) payments. The whitepaper serves as a comprehensive resource of information, which covers the detailed background on the launch of the CGDP through the on-going impact the program has had on beneficiaries, plan sponsors, and manufacturers.
The whitepaper begins by explaining the backdrop of the CGDP and its lifecycle to date; as to put all things in perspective, it’s important to understand the impact this program has had on the overall U.S. economy as well as each individual stakeholder group. The program, GCDP, has helped many patients gain access to life changing medications they previously struggled to afford while in the Coverage Gap, also known as the “Donut Hole”; having that perspective in mind we realize this program is here to stay. However, with the program having launched quickly, after enacted into law a little under three years ago, it continues to face growing pains from an administrative processing standpoint, as a result, changes continue to evolve. Manufacturers must continue to quickly adapt to these ongoing changes. Paragon Solutions’ whitepaper, “Key Considerations for Effective Processing of the Coverage Gap Discount Program (CGDP)”, highlights these complex issues for manufacturers before moving on to the role of adjudicating the CGDP payments.
A sneak peek of one of the examples discussed in the whitepaper is the “Negative Invoice Reconciliation” guidance published by CMS in mid-2013. The first negative invoice began hitting manufacturers as of the second quarter of the 2011 billing cycle. However, the guidance was not published by CMS mid-2013.
Manufacturers are again tasked with quickly adjusting to these changes and working to reconcile negative invoices they have been accumulating for almost two years. Manufacturers are also charged with following strict terms and timelines set by CMS through legally binding CGDP agreements. Compliance under these agreements is crucial to preserve and protect the Manufacturers’ existing Medicare Part D business. Because of this adaptation to these changes it is a necessity, not an option.
Constantly reacting to change can become cumbersome, but with the right processes and systems in place manufacturers have the means to quickly adapt. The whitepaper further focuses on the manufacturer’s perspective by elaborating on key fundamental considerations, tips, strategies, process recommendations, and ideas on how to gain insights through the data. With the nature of this program and its changes overtime solutions initially put in place by manufacturers to support this deserve a through look back on potential gaps process or improvements needed.
Shannon Bermudez is a Principal Consultant in the Revenue Management Practice under the Life Sciences Vertical at Paragon Solutions. Throughout Shannon’s 18 year tenure in the Life Sciences and Pharmaceutical industry she has developed both practical and strategic subject matter expertise in the pricing and contracting area. Shannon is a thought leader with in-depth knowledge and experience in all realms of pharmaceutical contracting specializing in: Commercial Managed Care, Medicare Part D, Medicare Part B, and Specialty Pharmacy/Distributor contracting.