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Comments on Medicare Drug Price Negotiation Program

Bottle of pills spilled onto hundred dollar bills.
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Editor's note:

The authors submitted the comment letter to the Centers on Medicare and Medicaid Services on June 26, 2025.

Richard Frank, Rachel Sachs, and Christen Linke Young provide The Centers for Medicare & Medicaid Services with comments on the recent Draft Guidance for the Medicare Drug Price Negotiation Program. The comment touches on four areas of the draft guidance:

  • Section 30.1: Identification of Qualifying Single Source Drugs (Combination Drugs)
  • Section 50.1: Forward-Looking Market Data
  • Sections 60.3.3 and 60.3.4: Factor Adjustment
  • Section 130: Renegotiation

Read the full comment letter

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