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Analysis of Most Favored Nation Final Rule

On November 20, 2020 the Trump Administration released an interim final rule with comment period (IFC) that would set reimbursement for 50 Part B drugs and biologics based on international pricing data using so-called “Most Favored Nation” (MFN) prices. At the same time, the policy would replace the current 6% add-on for affected drugs with a flat dollar add-on per dose. This memorandum provides our analysis of the policy changing add-on payments for Part B drugs under the policy.


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