X

Phia Group

rss

Phia Group Media


New Requirements Under the Mental Health Parity and Addiction Equity Act (“MHPAEA”)

On November 20, 2024

By: Kendall Jackson, Esq.

The deadline to comply with several of the new final rules regarding the Mental Health Parity and Addiction Equity Act (“MHPAEA”) is quickly approaching. On September 9, 2024, the U.S. Departments of Health and Human Services (HHS), Labor, and the Treasury released new final rules that updated existing regulations to provide additional clarity for plans and their vendors on what is required and what will be considered compliant and non-compliant for parity purposes when performing a nonquantitative treatment limitation (NQTL) comparative analysis. The final rules generally apply to group health plans, including self-funded non-Federal governmental health plans that, prior to the issuance of these rules, were able to opt out of MHPAEA compliance. The extension of MHPAEA’s application to self-funded non-Federal governmental health plans is beneficial to ensure that no plan may impose an NQTL with respect to mental health or substance use disorder (“MH/SUD”) benefits in any classification that is more restrictive, as written or in operation, than the predominant NQTL that applies to substantially all medical/surgical (“M/S”) benefits in the same classification. Of the newly outlined rules, most apply to group health plans on the first day of the first plan year beginning on or after January 1, 2025.

The final rules codify that health plans must perform a comparative analysis, which must include an evaluation of NQTLs for network composition, out-of-network reimbursement rates, medical management standards, and prior authorization, as well as six additional elements, such as a description of the NQTL, identification of and definitions for the factors and evidentiary standards used to design or apply the NQTL, and a description of how factors are used in the design or application of the NQTL. The final rules also outline certain responsibilities for plan fiduciaries. The final rules require certification confirming the plan fiduciary’s engagement in a prudent process to select one or more qualified service providers to perform and document a comparative analysis in connection with the imposition of any NQTLs that apply to MH/SUD benefits under the plan in accordance with MHPAEA and its implementing regulations, as well as satisfaction of the duty to monitor those service providers. At a minimum, the Department of Labor expects that the plan fiduciary will review the comparative analysis, ask questions about the results, discuss the results with those who drafted it, if necessary, and ensure that the service provider conducted the comparative analysis in compliance with MHPAEA.

Separate from those requirements listed above, the implementation of several other requirements is delayed until January 1, 2026. This includes the meaningful benefits standard, which requires that if a plan provides any benefits for an MH/SUD condition in any of the six benefit classifications, it must provide “meaningful benefits” for that condition or disorder in every classification in which meaningful M/S benefits are provided. Also delayed are the regulations requiring plans to satisfy the design and application requirements, which include the prohibition on discriminatory factors and evidentiary standards, and the relevant data evaluation requirements, which involve collecting and evaluating relevant data to assess the impact of NQTLs on access to MH/SUD benefits and M/S benefits. Any requirements for the provisions of the comparative analyses related to the delayed requirements are also deferred until January 1, 2026.

While several of these new requirements are not applicable for quite some time, plans that cover both M/S benefits and MH/SUD benefits and impose NQTLs on MH/SUD benefits should be sure to perform and document a comparative analysis of the design and application of each applicable NQTL in a manner consistent with the new final rules. The Departments have yet to provide how often these comparative analyses should be performed, but rather state that they should be kept current. We generally interpret this to mean that they should be performed annually based on the fact that the plan is updated annually.

A New Year, a New Administration, but the Same Old Problem?

On November 19, 2024

On Friday, November 1, millions of Americans awoke from their Halloween slumber only to be further spooked by a New York Times report that employers expect the costs of health benefits to surge as much as 9 percent on average in 2025. How much will the outcome of this month’s elections – held during many companies’ open enrollment period -- impact this now decades-long industry trend? What does this all mean for plans interested in covering big-ticket items like weight loss drugs and next-generation gene therapies in the new year? As 2024 soon merges into 2025, join The Phia Group’s webinar as its panel of experts break down how election results will impact the industry and look ahead to what compliance changes are afoot in just over a month ahead. Indeed, this is a crucible moment for the healthcare industry – and Phia’s Independent Consultation & Evaluation (ICE) team looks forward to lending its expertise.

Click Here to View Our Full Webinar

To obtain a copy of our webinar slides, please reach out to [email protected].

Navigating Balance Billing and Post-Payment Disputes: Solutions for TPAs and Self-Funded Employers

On November 14, 2024

By: Scott Bennett and David Ostrowsky

As rising healthcare costs continue to challenge employers and third-party administrators (TPAs), Reference-Based Pricing (RBP) has emerged as a powerful strategy for cost containment. However, RBP, while promising, is not without its pitfalls. Chief among them is balance billing, in which providers charge patients for the difference between their billed charges and the RBP plan’s payment. Additionally, the No Surprises Act (NSA) has introduced Open Negotiations and Independent Dispute Resolution (IDR) processes, which, while protecting patients, expose employers to post-payment disputes. Addressing these concerns effectively requires comprehensive tools, support, and strategic implementation.

Addressing the Challenges of RBP Programs and NSA Requirements

RBP programs use reference points such as Medicare rates to create more predictable and transparent pricing. While this can reduce healthcare costs and broaden provider options, it also exposes plan participants to potential balance billing when providers reject the RBP payment as full settlement and bill the patient for the remaining balance. This creates financial stress for both patients and employers.

The introduction of the NSA further shifts the focus of payment disputes from patients to employers. Open Negotiations and IDR processes require a deep understanding of regulations, adherence to strict timelines, and awareness of critical benchmarks necessary to successfully argue, negotiate, and defend cases. TPAs and self-funded employers must navigate these processes carefully to mitigate risk and manage potential exposure.

 How Comprehensive RBP Solutions and NSA Expertise Mitigate Risks

1. Effective Balance Bill Resolution 

Choosing an RBP solution that offers strong balance bill resolution is critical. Programs that include direct intervention and independent legal support can prevent unexpected financial burdens on employees and reduce the administrative load on employers and TPAs. Care Empowered Pricing, for instance, includes this type of support, leveraging years of experience in resolving balance billing issues effectively and adapting to the evolving regulatory landscape under the NSA.

2. Expertise in NSA Open Negotiations and IDR 

Handling Open Negotiations and IDR requires more than basic dispute resolution skills. Employers need an informed and experienced team that understands the regulations, adheres to strict timelines, and recognizes the important benchmarks necessary to advocate successfully. Solutions that provide this level of expertise ensure that employers are prepared to navigate these complex processes and defend their positions effectively, minimizing exposure and ensuring compliance.

3. Empowered Provider Selection 

The use of advanced provider data and selection tools can greatly enhance the success of an RBP program. By using technology-enabled repricing engines, TPAs can glean insights into provider practices and payment acceptance, thereby steering employees toward providers more likely to accept reference-based payments without triggering balance bills. This also helps reduce the frequency of disputes requiring NSA Open Negotiations or IDR processes.

4. Member Education and Support 

Educating employees about how their RBP plan functions and how to identify compliant providers is essential. Solutions that offer real-time support and guidance ensure that members are confident and well-prepared when navigating healthcare services. Additionally, having a well-informed and experienced team capable of reacting swiftly, reaching out, and using technology based on practical experience to track and resolve cases is vital. Care Empowered Pricing emphasizes member education and continuous access to resources in order to bolster awareness of the NSA processes.

Best Practices for Preventing and Resolving Balance Bills and Navigating NSA Processes

Preventing and addressing balance billing and post-payment disputes is essential for the success of any RBP program. Key practices include:

  • Transparent Communication: Offering employees detailed, region-specific pricing guides to inform their decisions and help them select providers aligned with plan terms.
  • Proactive Legal Support and Regulatory Adherence: Leveraging embedded legal advocacy and ensuring strict adherence to NSA requirements and timelines to protect members and employers when disputes arise.
  • Experienced Team and Technology Integration: Ensuring a team is in place that can respond effectively, leverage technology, and use experience to manage and resolve cases promptly, including those involving Open Negotiations and IDR processes.

Why Enhanced RBP and NSA Solutions Matter

For TPAs and self-funded employers, selecting an RBP solution that encompasses customizable pricing, experienced advocacy, and continuous member support—while also incorporating expertise in NSA regulations and dispute resolution—is essential. Solutions like Care Empowered Pricing deliver comprehensive approaches, ensuring that participants are informed, supported, and protected from balance billing challenges and that employers are well-equipped to handle post-payment disputes. This creates a more sustainable, efficient, and fair approach to healthcare pricing and compliance that benefits all stakeholders.

By integrating these strategies into their RBP programs, TPAs and employers can enhance participant experiences, reduce financial risks, and build a healthcare framework centered on transparency, fairness, and robust regulatory compliance.

Empowering Plans: P205 – Lessons From a Florida IDR Case

On November 5, 2024

On this episode of the Empowering Plans Podcast, attorneys Ron Peck and Nick Bonds talk through a recent Florida case addressing judicial review of IDR determinations and highlight some of the key insights and takeaways for any entity subject to the No Surprises Act.

Click here to check out the podcast! (Make sure you subscribe to our YouTube and Apple Podcasts Channels!)

Having NSA Problems? Better Call The Phia Group

On October 31, 2024

By: David Ostrowsky

The Independent Dispute Resolution (“IDR”) process was designed to be a cornerstone of the No Surprises Act (“NSA”), a means for resolving claims for payment for out-of-network items and services and a vital mechanism for buttressing the NSA’s protection for plan members against potentially devastating balance billing expenses. Unfortunately, since the NSA took effect on January 1, 2022, things have gone awry on many fronts.

The case volume has overloaded the IDR process; courts have been split over whether and how parties can enforce arbitration awards; payers, including group health plans, have paid close to four times as much for services as CMS rates. Ultimately, the confluence of these troubling dynamics  threatens to undermine the original intent of the NSA and elevate costs for all.

In fact, in the most recent edition of JAMA Internal Medicine, a prominent monthly peer-reviewed medical journal published by the American Medical Association, authors Kevin A. Schulman, MD and Barak Richman, JD, PhD, provided indisputable evidence that prices stemming from IDR decisions closely align with what providers – many of whom belong to private equity-backed practices -- have requested, vastly exceeding Medicare rates and prior in-network commercial market prices. As just one example, Schulman and Richman report median IDR decisions (from Q1 and Q2 2023) for three categories of services – emergency care, imaging, and neonatal/pediatric critical care – that surpass Medicare prices by a factor of 3.7 or more for all three service types. Clearly, the NSA has not curtailed exploitive business practices and at this time, there still aren’t any implementing rules in force, as arbitrators continue to operate with minimal substantive guidance in trying to resolve price disputes.

Subsequently, now, more than ever, it is of paramount importance to understand how such developments will impact your self-funded health plan. Handling NSA claims is, after all, still a relatively new process, one largely bereft of transparency, and many plans are understandably struggling to manage open negotiations and subsequent IDR procedures. In this regard, The Phia Group, with its battle-tested processes for deftly handling NSA claims and appeals and utilization of intelligent out-of-network pricing methodologies, benchmarking and cutting-edge appeal review software, can provide immeasurable value.

“Unlike the rest of the organizations in this industry that provide NSA services, our reputation was built on ensuring that all regulatory, compliance and plan design needs are focused on first,” explains Phia CEO Adam V. Russo. “This includes understanding the processes and tools that administrators have in dealing with the vastly different deadline and notification aspects of the NSA. We know it, we built our software around it and our extensive team of experts ensures that we meet every set of standards needed for a successful NSA program, including coordination of stop loss carriers. 

“There is no other firm with repricing capabilities that can match our reputation and outcomes when it comes to navigating the legal complexities that this service requires.”

Some of the core reasons why Phia’s IDR support service achieves optimal results:  

  • Experts who over the past three years have developed an efficient process for handling NSA claims and can expeditiously manage critical documents involving communications (i.e., those to clients to facilitate informed decision making), billing, and evidence. In addition, strong familiarity with the NSA timelines and stages, so there is the ability to quickly prioritize without wasting time. Subsequently, procedural issues are resolved with strict adherence to timelines (i.e., deadlines to responding to IDR initial selection and submitting a final offer) 
  • In addition to attorneys, case handlers who have the real-world procedural NSA experience to thoroughly comprehend benchmarks, coding, and evidence so they’re not going into any situation uninformed, even for complex high-dollar cases. Leveraging industry-standard coding, provider quality metrics, and offers grounded in indisputable, objective evidence reduces unnecessary costs while maximizing savings.
  • Phia Ignite, a tool engineered to help health plans navigate the complexities of the NSA, including IDR, and mitigate financial risks by providing defensible payment strategies and supporting balance bill resolution work.

“With a powerhouse team of seasoned attorneys, certified medical coders, data-savvy analysts, and skilled negotiators, Phia is uniquely equipped to handle straightforward NSA claims with precision and seamlessly scale to expert-level solutions for the most complex cases,” added Scott Bennett, Phia’s Senior Vice President of Provider Relations.

Undeniably, the IDR process continues to be riddled with significant ambiguity and opacity but The Phia Group, for the aforementioned reasons along with many others, has the resources to help you navigate the chaos.

The Future of Birth Control in America

On October 28, 2024

By: David Ostrowsky

Since the US Supreme Court decided to undo nationwide abortion rights in summer 2022, women’s reproductive rights has arguably been the most pressing topic in healthcare. Naturally, as we enter the final stretch of election season – as well as the Biden administration – the all-important, polarizing matter has resurfaced.

Earlier this month, the departments of Health and Human Services, Labor and Treasury proposed to broaden a federal mandate (under the Affordable Care Act) obligating private health insurers to cover condoms, birth control pills, and “morning after” pills for women on private health insurance plans – even without a prescription. Currently, health insurers are mandated to cover only the cost of prescribed contraception; should the new rule become law next year, over 50 million more American women on private health insurance plans would be able to go to their local drugstores and pharmacies and purchase these items, irrespective of whether or not they were prescribed. Accordingly, private health plans would also be required to disclose to women that those contraceptives are covered without cost-sharing.

Taking a deeper dive into the proposed rule, it’s apparent that there’s more than just the matter of whether or not a pill is prescribed. Under the Biden administration’s plan, insurers would have to cover all FDA-approved drugs and drug-led combination products, unless the plans also cover a therapeutic equivalent. Therapeutic equivalents, per the FDA, are drugs that have an identical amount of the same active ingredient. At this hour, insurers only need to cover one drug per category of contraception — which could be birth control pills, implants or IUDs — causing some women to have difficulty accessing the precise combination of drugs in the type of prescription contraceptive they so desire.  

Practically speaking, the Biden administration’s proposal could have life-changing consequences for large swaths of the female population in this country. The emergency contraceptives that women on private insurance plans would be able to access without cost – and prescription – most notably include levonorgestrel, more commonly known by the brand name “Plan B,” which is a pill that must be taken immediately after intercourse to prevent pregnancy. As it currently stands, when women don’t have a doctor’s prescription, they may pay as much as $50 for a pack of the pills. Thus, women who may feel inclined to delay purchasing the medication until they get a doctor’s prescription could be compromising the efficacy of the pill – perhaps without even being aware. Moreover, if this new rule is in fact implemented, insurers would have to assume the full cost of Opill, a new OTC birth control pill that the FDA approved last year. A one-month supply of Opill costs $20, perhaps not an extravagant price but nonetheless one that may be prohibitively expensive for some.

Vice President Kamala Harris, who has affixed her presidential campaign to a pledge to embolden women’s healthcare rights, trumpeted her administration’s proposal, declaring in an official statement:

“Every woman in every state must have reproductive freedom and access to the health care they need. That is why I have fought to lower health care costs and protect the ability of every woman to make her own decisions about her own body."

 
“Today, our Administration is proposing the largest expansion of contraception coverage in more than a decade. This new proposed rule will build on our Administration’s work to protect reproductive freedom by providing millions of women with more options for the affordable contraception they need and deserve.”

Since the passage of the Affordable Care Act, women have saved billions of dollars that they would otherwise have spent on contraception. But now, for the first time in the history of the United States there is strong potential for universal coverage for no-cost, over-the-counter, no-prescription-necessary contraception, which would save even more billions.

Empowering Plans: P204 – Nightmares on Self-Funded Street

On October 24, 2024

Join Attorneys Corey Crigger and Kendall Jackson on this Halloween edition of the Empowering Plans Podcast. Corey and Kendall take a look at topics that send shivers down the spine of the self-funded industry. How do you protect your plan from the scary cost of gene therapies? What will the rapidly advancing AI sector mean for you and your clients? What is the best trick or treat candy? Tune in to find the answers to these questions and many more on the Empowering Plans Podcast.

Click here to check out the podcast! (Make sure you subscribe to our YouTube and Apple Podcasts Channels!)

Industry Crossroads – How the 2024 Election Impacts You & Major Implications For Our Industry

On October 17, 2024

Although healthcare hasn’t stolen the limelight as it did in past elections, those “in the know” know that the results of this historic election will have a major impact on healthcare and health benefit plans alike. Between soaring drug costs, increased fiduciary litigation, the impact of A/I, and growing popularity of weight-loss drugs (which is likely to escalate as the year ends), to thrive in 2025 and beyond industry insiders must understand the current state of the market as well as predict what is to come.  Join us as we discuss these and other pressing issues.  Also, speaking of A/I, our team will present a live demonstration of SoPhia, our very own chatbot, which will engage with audience questions. 

Click Here to View Our Full Webinar

To obtain a copy of our webinar slides, please reach out to [email protected].

The Phia Group's 4th Quarter 2024 Newsletter

On October 16, 2024


Phone: 781-535-5600 | www.phiagroup.com


The Book of Russo:

Halloween is my favorite holiday of the year, though my reasoning has evolved over time. Back in the day, I used to love wearing a cool costume and going trick or treating in my neighborhood. Could anything beat the combination of free candy, time with friends, and fresh air? Today, however, Halloween is no longer about serving myself, and rather, is about bringing joy to my own children and our neighborhood kids. That passion to serve others drives me to – according to my wife – go a little too far. Each year I basically build a haunted house in my front yard, for the entertainment of the hundreds - yes I said hundreds - of kids that stop by and care to be spooked by my many scary decorations and animatronics…

It's gotten to the point that people from other neighborhoods come to mine just to see what I have in store that year. At this point, you may be asking what this has to do with The Phia Group, health insurance, benefit plans, or any of the other pressing topics and innovative services that Phia has to offer. I mean, election day is upon us, laws are changing, litigation is pending, regulations are evolving… At first blush, you’ll say my story is unrelated… but you’d be wrong. Watching hard work translate into joy; investing time and effort into serving others; it all boils down to one important thing – passion.

Just as my passion for Halloween has expanded and grown to include a larger community, so too has my passion for this industry expanded and evolved. Moreover, a passion for serving others is paired with a passion to compete! I'm out there trying to outdo the neighbors. I need to have the coolest set up in town with the latest items and features. The same can be said for The Phia Group as well. Yes; we are focused on reducing the cost of care while improving quality outcomes, but we also want to be the best at what we do. We are passionate about every service, every feature, every new piece of technology and we want to share it – both our services and our passion – with the industry. Just like I want to share my love of Halloween with my neighborhood. What a treat!!! Well I hope you have lots of children dressed up and ringing your doorbell this October 31st. I can't wait to see the creativity in some of the costumes just like you all enjoy the creativity of our plan documents.

It's a great time of year - happy reading.


Service Focuses of the Quarter
Phia Fit to Print
From the Blogosphere
Webinars
Podcasts
The Phia Group’s 2024 Charity
Employee of the Quarter
Phia News

Service Focus of the Quarter: Phia Unwrapped (featuring Phia Ignite)

Wrap networks? More like Cr-- well, they’re not great, anyway. Instead of that antiquated and widely despised fallback for OON claims, Phia Unwrapped is a better, smarter, more cost-conscious way to manage those claims. 

Powered by the expertly crafted Phia Ignite Repricing Engine, Phia Unwrapped boasts best-in-class claims repricing and comprehensive patient-centric balance billing support with the full weight and skillset of The Phia Group behind it. 

If you haven’t used, seen a demo of, or heard great things about Phia Unwrapped, we urge you to email [email protected] today. (Your bank account will thank you.)  

Enhancement of the Quarter: SoPhia  

The Phia Group’s great consulting and technology minds have continued to refine our artificial intelligence (AI) tool, SoPhia, which is expertly trained using documentation curated explicitly for SoPhia. This is unique in that SoPhia is trained exclusively with Phia’s own consulting expertise and carefully curated third-party sources in order to maximize the quality of SoPhia’s responses. 

We're excited to announce that two of our clients are now participating in the beta testing phase, exploring how SoPhia can streamline tasks and disseminate information in a helpful way. 

We’ve engineered SoPhia to help improve the ICE service for all users, whether directly or indirectly, and the beta testing program is a step toward broader usage. We look forward to expanding SoPhia’s capabilities and we’re eager to eventually roll it out to all our ICE clients!

Phia Case Study: Third Opinions  

Note: this is not one single case study, but a conglomeration of many similar ones. 

Medical reviews have become an integral part of claims and appeals adjudication, and with good reason: employers are not clinicians (. . . unless the group is literally a group of clinicians). But what happens when a medical review is performed on an initial claim and yields one result, and then a different medical review is performed on appeal and yields the opposite result? Does the plan necessarily have to trust the second opinion? If it differs from the first opinion, who’s to say that the second one is more correct than the first? 

The answer depends on the circumstances, but like so many things, the plan has to make sure that it’s being reasonable in its administration of this type of issue. For instance, some plans continue to rely on an initial medical review (which supports the benefit exclusion) through the entire appeals process, but that’s likely a violation of the appeals regulations that require a new review on appeal. Other plans seek a second medical review on appeal, and operate based on the second, more recent medical review. Other plans still look for a “tiebreaker” medical review when the initial two conflict; the process has to end somewhere, after all. 

Though we are generally of the opinion that either of the second two options is compliant (that is, rely on the later medical review on appeal, or rely on the “tiebreaker” when the initial two conflict), we can say with confidence that relying on a single medical review that supports the claim denial throughout the entire appeals process is not compliant. 

This is one of the draws of The Phia Group’s Plan Appointed Claim Evaluator (PACE) service: whenever there’s a clinical question, we have a new medical review performed, so you never need to worry that you’ve relied on the same review the whole way through the process!  

Fiduciary Burden of the Quarter: Aligning the SPD with Network Contracts

Too many times, Phia’s consulting team has encountered Plan Documents that say in no uncertain terms that all claims payments will be limited to some sort of U&C-based amount. That’s fine, of course, but only if it’s accurate! Unfortunately, if a claim is subject to a network contract, that U&C limitation can’t be applied, and the SPD language becomes accidentally incorrect. 

Though it’s unlikely that anyone will complain about a technical SPD violation when the provider and patient are both happy because a claim is paid at the network rate instead of the lower rate specified in the SPD, it’s nonetheless a breach of the fiduciary’s duty to fail to not administer the plan strictly in accordance with the SPD – not to mention that stop-loss carriers generally don’t reimburse claims paid at amounts higher than the SPD allows, regardless of the fact that the employer has separately agreed to make the higher payment via its network contract. 

Luckily, there’s a simple fix for this: to make sure the SPD remains accurate with respect to contracted claims payments while keeping its strong cost containment for non-contracted claims. Our preference is something simple, such as defining the payable rate as “a negotiated rate, if one exists,” and then falling back to the other cost containment methods if there’s no negotiated rate. 

It’s very important for a fiduciary to do exactly what the SPD says – so we urge employers and those who service them to be diligent about making sure the SPD language is accurate with respect to claims payments.


_

Webinars:

• On August 19, 2024, The Phia Group presented “Don't Be Surprised - Phia's Keys to Success with The No Surprises Act and Appeals Management,” in which we discussed our unique, battle-tested processes for handling NSA claims and appeals. 

• On July 16, 2024, The Phia Group presented “The Impact of Provider Trends on Stop-Loss and Plans,” in which we discussed how to counterbalance rising prices as well as navigate increasingly complex interactions with stop-loss.

Be sure to check out all of our past webinars!


Podcasts:

Empowering Plans

• On September 27, 2024, The Phia Group presented “Senator Sanders: “Stop ripping us off,” in which our hosts, Brady Bizarro and Andrew Silverio, discussed senate committee hearing on GLP-1 drug pricing and strategies that self-funded employers are using to manage the extreme costs of these drugs while we wait and hope for congressional action. 

• On September 12, 2024, The Phia Group presented “Diving Into the Parity Pool: MHPAEA’s Latest Updates,” in which our hosts, Jennifer McCormick and Bryan Dunton, discussed several critical considerations for plans as renewal season approaches. 

• On September 5, 2024, The Phia Group presented “Recognizing Our Blind Spots” in which our host, Adam V. Russo, was joined by our special guest, Dr. Marty Makary. Listen in as they discuss his new book, Blind Spots: When Medicine Gets It Wrong, and What It Means for Our Health. 

• On August 29, 2024, The Phia Group presented “Summer Regulation Rundown,” in which our hosts, Kelly Dempsey and Nick Bonds, discussed some of the big rules we’re looking forward to as the clock gradually runs out on the Biden administration and the challenges they may face. 

• On August 15, 2024, The Phia Group presented “Healthcare on the Ballot,” in which our hosts, Nick Bonds and Corey Crigger, discussed the impact that each administration could have on the self-funded industry and the country. 

• On August 1, 2024, The Phia Group presented “The Concerns About PBMs and the Demand for Reform,” in which our hosts, Jon Jablon and Kendall Jackson, broke down the consequences of PBM steerage. 

• On July 18, 2024, The Phia Group presented “Exploring Claims Processing Models,” in which our hosts, Andrew Silverio and Cindy Merrell, delved into the pros and cons of the pay and chase versus pend and pay models of claims processing. 

• On July 2, 2024, The Phia Group presented “SCOTUS Decisions: Harrington and Loper's Impact on Healthcare,” in which our hosts, Brady Bizarro and Corey Crigger, broke down two of the most significant Supreme Court cases just decided this term – the Harrington case and the Loper case.

Be sure to check out all of our latest podcasts!



Back to top ^


Phia Fit to Print:

• Worklife News – From ‘Tinder Leave’ to Pet Insurance, Employers Get Creative with Benefits – September 2024 

• Medium – Driving Disruption: Adam V Russo Of The Phia Group On The Innovative Approaches They Are Taking To Disrupt Their Industry – September 2024 

• Dorchester Reporter – ‘Dot kid done-good’ funds a scholarship at Suffolk – August 2024

Back to top ^


From the Blogoshpere:

What the Overturning of Chevron Means for Healthcare. Learn about the Supreme Court’s 1984 decision in Chevron U.S.A., Inc. v. Natural Resources Defense Council. 

Health Over Wealth. It has become fairly common practice for PE firms to acquire a struggling healthcare facility or physician practice, one desperately in need of capital and management expertise. 

Healthcare in Rural America. Healthcare inequality is a glaring problem across our nation, but the issue is particularly acute in rural America where folks grapple with a perfect storm of factors restricting access to medical facilities. 

Section 1557 Final Rule: Where Do We Stand? The implications of the Section 1557 Final Rule are currently in flux since the Final Rule was issued on April 26, 2024. 

The First Ten: Medicare Unveils Inaugural List of Negotiated Drug Prices. Will drug prices be coming down in the near future?

To stay up to date on other industry news, please visit our blog.

Back to top ^


The Phia Group's 2024 Charity

At The Phia Group, we value our community and everyone in it. As we grow and shape our company, we hope to do the same for the people around us.

The Phia Group's 2024 charity is the Boys & Girls Club of Metro South.



The mission of The Boys & Girls Club is to nurture strong minds, healthy bodies, and community spirit through youth-driven quality programming in a safe and fun environment.

The Boys & Girls Club of Metro South (BGCMS) was founded in 1990 to create a positive place for the youth of Brockton, Massachusetts. It immediately met a need in the community; in the first year alone, 500 youths, ages 8 to 18, signed up as club members. In the 30-plus years since then, the club has expanded its scope exponentially by offering a mix of Boys & Girls Clubs of America (BGCA) nationally developed programs and activities unique to this club.

Since their founding, more than 20,000 youths have been welcomed through their doors. Currently, they serve more than 1,000 boys and girls ages 5-18 annually through the academic year and summertime programs. 

Silent Auctions at SIIA National

At this year’s SIIA National event, Phia auctioned off a stunning painting by Rich Hunt, our Facilities Manager. The auction saw competitive bidding over two days, and Heather Schiappacasse emerged as the final winner. Additionally, Kelly Russo’s painting was auctioned off at our cocktail party, which was won by Danny Schwarz. The paintings raised over $1,300, with all proceeds going to support the Boys & Girls Clubs of Metro South. A big thank you to everyone who participated!


2024 Volunteer Day

The Phia Group had the opportunity to visit the Boys & Girls Clubs of Metro South to participate in some fun activities for the kids! With over 100 kids to entertain all day, we had plenty for people to do. Temporary tattoos, tie-dye, face painting, hiking, and so many more activities filled the day with so much joy and left us with so many memories. We are looking forward to next year’s Volunteer Day!


2024 Louisville Volunteer Day

Our Louisville team was out and about this past summer, volunteering at The Boys & Girls Club of Kentuckiana. They hosted a Water Wonderland event for the kids that included face painting, a water slide, sprinklers, water balloon/cannon games, and more. We hope you all had a great time and can’t wait to do it all again next year!


Backpack & School Supply Drive

We just wrapped up our annual backpack & school supply drive with The Boys & Girls Club of Metro South. Our staff collectively donated items and/or money to purchase supplies for 150 kids (ages 5-18). In total, we donated over 3,000 items . . . 3,304 to be exact.


Leukemia & Lymphoma Society

As a tireless supporter of the Leukemia & Lymphoma Society, The Phia Group, behind Chief Legal Officer, Ron E. Peck (Mission Award Winner – Research), was extremely proud to be a leading sponsor of this year's Boston Metro Visionary of the Year campaign. We are also thrilled to report that Ron's efforts placed him in the top five all-time fundraisers for this campaign and were a major reason why this turned out to be a record-breaking year. We look forward to continuing this wonderful partnership for many years to come.

Back to top ^


Phia News: 

Phia On Fire at SIIA National

The Phia Group brought incredible energy to this year’s SIIA National event! If you were there, you likely heard the buzz of cowbells coming from our booth. We had it all: hot sauce tastings, live painting sessions, and live demos of our new software. It was an exciting, interactive experience, and we can’t wait to do it all again in 2025!

Phia’s New Software 

The Phia Group was proud to showcase four innovative software demos at the SIIA National Conference in Phoenix, AZ. These demos highlighted the latest tools designed to optimize healthcare cost containment and plan management: 

• Care Empowered Pricing (CEP): Revolutionizing cost savings through smarter pricing strategies. 

• Phia Appeals Management System (PAMS): Streamlining the appeals process for better efficiency. 

• SoPhia: A sophisticated platform for actionable insights and automation. 

• Phia Unwrapped: A cutting-edge service for unbundling and identifying hidden costs. These tools demonstrate Phia’s commitment to leading innovation in the industry. Check out our new demos, here: https://vimeo.com/1018445477/91a84ffba1

Phia on the News

The Phia Group’s CEO, Adam V. Russo, appeared on Boston 25 News to discuss the incredible partnership with The Boys & Girls Club of Metro South. He shared his personal story of his involvement with the club as a child and expressed how meaningful it is to give back to the organization that helped him in his youth.


Get to Know Our Employee of the Quarter: Alex Houle

Being named Employee of the Quarter is an achievement that is for Phia employees who truly go above and beyond their responsibilities. This person must not only transcend their established job description but also demonstrate such unparalleled dedication and passion to The Phia Group and its employees that it cannot go without recognition. 

The Phia Explore team unanimously agrees that there is no one more deserving than Alex Houle to be recognized as The Phia Group’s Employee of the Quarter for Q3 of 2024.


Congratulations, Alex, and thank you for your ongoing and future contributions.


Job Opportunities:

• Sr. Claims Recovery Specialist 

• Office Assistant (Accounting) 

• Claims Recovery Specialist – Mass Tort 

• Case Investigator

See the latest job opportunities, here: https://www.phiagroup.com/About-Us/Careers

Promotions

• Bill Parlee has been promoted from Claims Recovery Specialist IV to Sr. Claims Recovery Specialist. 

• Nicholas Walsh has been promoted from Case Investigator to Sr. Claims Recovery Specialist 

• Jessica Grande has been promoted from Team Lead, Project Coordinator to Manager, Projects & Operations

New Hires

• Kendall Felici was hired as a Project Coordinator 

• Brad Hall was hired as a Sr. Claims Recovery Specialist 

• Bradley Lynch was hired as a Case Investigator 

• Ben Chute was hired as a Salesforce Consultant 

• Samantha Canestraro was hired as a Claims Recovery Specialist 

• Hannah Coffey was hired as a Case Investigator 

• Immanuel Allen was hired as a P/T Office Administrator 

• Lakshmi Sreenevasan was hired as a VP, Data Services, Analytics and Automation 

• Justin Forton was hired as a Client Success Account Executive 

• Tamika Virgil was hired as a Customer Service Rep 

• Keri Potter was hired as a Customer Service Rep 

• Julie Wisch was hired as a Customer Service Rep 

• Tabyrius Baldwin was hired as a Sr. Claims Recovery Specialist 

• Brianna Sullivan was hired as a Customer Service Rep


The Phia Group Reaffirms Commitment to Diversity & Inclusion

At The Phia Group, our commitment to fostering, cultivating, and preserving a culture of diversity and inclusion has not wavered from the moment we opened our doors 20 years ago. We realized early on that our human capital is our most valuable asset, and fundamental to our success. The collective sum of individual differences, life experiences, knowledge, inventiveness, innovation, self-expression, unique capabilities, and talent that our employees invest in their work, represents a significant part of not only our culture, but also our company’s reputation and achievements.

We embrace and encourage our employees’ differences, including but not limited to age, color, ethnicity, family or marital status, gender identity or expression, national origin, physical and mental ability or challenges, race, religion, sexual orientation, socio-economic status, veteran status, and other characteristics that make our employees unique.

The Phia Group’s diversity initiatives are applicable to all of our practices and policies, including recruitment and selection, compensation and benefits, professional development and training, promotions, social and recreational programs, and the ongoing development of a work environment built on the premise of diversity equality.

We recognize that the success of our company is a direct reflection of each team member’s drive, creativity, diversity, and willingness to exercise initiative. With this in mind, we always seek to attract and develop candidates who share our passion for the healthcare industry and our commitment to diversity and inclusion.

Back to top ^

[email protected]
781-535-5600

Empowering Plans: P203 – Gender-Affirming Care, Is it Covered?

On October 15, 2024

On this episode of the Empowering Plans Podcast, attorneys Jon Jablon and Cindy Merrell explore the changing landscape of several state and federal laws that affect coverage of gender-affirming care.

Click here to check out the podcast!
(Make sure you subscribe to our YouTube and Apple Podcasts Channels!)

Cobenfy: A Potential Game-Changer for Schizophrenia Patients – But at What Price?

On October 9, 2024

By: David Ostrowsky

As you’re reading this blog, millions worldwide are suffering from the horrors of schizophrenia, one of the most complex, debilitating, and stigmatized mental disorders inflicted on humanity, the symptoms of which typically manifest themselves in early adulthood, though they are not always so easy to detect. Those afflicted by this condition are desperately trying to manage an array of frightening symptoms (hearing voices, delusions, memory lapses to name a few) while carrying on with their lives. In this country alone there are approximately 2.8 million Americans living with schizophrenia; tragically, many of those 2.8 million Americans won’t be living much longer as there is a particularly acute rate of suicide among people battling schizophrenia. Meanwhile, so many others suffering often experience prolonged bouts of homelessness and/or run afoul of the law. And for decades, pharmacological innovation has moved at such a glacial pace that treatment has largely yielded inadequate improvement in symptoms and/or intolerable side effects during therapy that many have felt inclined to discontinue usage.

Starting this month, however, game-changing relief may be forthcoming. After 70 years of incremental progress, the FDA has greenlighted Bristol Myers Squibb’s new drug to treat schizophrenia, Cobenfy, which promises to alleviate said conditions while averting debilitating side effects previously associated with schizophrenia medications such as incontrollable weight gain, involuntary muscle jerking, and heightened risk for diabetes. In contrast to earlier iterations of antipsychotic medications that targeted dopamine receptors, the twice-a-day pill Cobenfy, the active ingredients of which are xanomeline and trospium chloride, works on cholinergic receptors. It’s a scientific breakthrough that could very well have a life-changing impact on this vastly overlooked, vulnerable population that, according to some estimates, exceeds 24 million people around the world. 

“There is now an entirely new pharmacological approach for schizophrenia — one that has the potential to change the treatment paradigm,” Chris Boerner, Ph.D., board chair and CEO at Bristol Myers Squibb, remarked following the FDA’s landmark approval. “As we reenter the field of neuropsychiatry, we are dedicated to changing the conversation around serious mental illness, beginning with today’s approval in schizophrenia.”

While Bristol Myers Squibb may be trumpeting the efficacy of Cobenfy, the soon-to-be released medication is not without its own considerable side effects, namely heightened risk for nausea, vomiting, and constipation, as evidenced by clinical trial results. Still, considering that many patients deem medications currently available for schizophrenia to be grossly ineffective, the emergence of Cobenfy as a viable alternative to existing treatments may be grounds for cautious optimism.

Of course, the larger, no-pun-intended million-dollar question is whether or not Cobenfy will be prohibitively expensive for the masses in dire need of relief. Indeed, Cobenfy carries a list price of $22,500 for a year’s supply before accounting for insurer rebates or discounts, which according to a Bristol Myers spokesperson, is priced “in line with the landscape of branded oral antipsychotics.” Apparently, the majority of schizophrenia patients are on Medicare or Medicaid and won’t pay the list price anyways, but what about those who are not on government-sponsored programs and don’t have the wherewithal to pay such imposing out-of-pocket costs? Will private insurers provide coverage for Cobenfy considering that the FDA has already approved over a dozen antipsychotic medications for schizophrenia that are on the market? Will these companies require patients to try their cheaper generic versions first before approving coverage of the far more expensive Cobenfy? (The FDA approved Cobenfy as a monotherapy—meaning it is meant to be taken alone, without other medications.)

“If it's like a lot of the other new medications, insurance is generally going to mandate that people try at least two generic medicines first … before they will pay for it [Cobenfy],” Dr. Jacob Ballon, an associate professor of psychiatry at Stanford University, told the Associated Press.

If such barriers are in place for an antipsychotic prescription, one has to wonder if is it within the realm of possibility that mental health parity violations surface.  

But for the time being, there is understandably a groundswell of hopefulness in the scientific and medical communities that the FDA’s recent approval of Cobenfy represents a watershed moment in psychiatric research. Should Cobenfy have the desired salubrious effects, it is quite possible, perhaps even likely that Bristol Myers Squibb will seriously explore other avenues for administering the medication, such as for treating Alzheimer’s-related psychosis, bipolar mania, Alzheimer’s-associated agitation, and Alzheimer’s-associated cognitive impairment.

Of course, though, first there needs to be a large enough sample size of the population to try Cobenfy for treating schizophrenia . . . which, in turn, means there needs to be reasonably priced coverage of the drug.

Healthcare and Politics… Ugh. Old News!

On September 27, 2024

By: Ron Peck, Esq.

Donald Trump recently stated that while he will never give up on repealing the Affordable Care Act (ACA), he was not running on terminating the ACA.  This is likely a smart decision, given that a recent Kaiser Family Foundation (KFF) poll[1] revealed that for Republican voters, repealing Obamacare was an important issue for a very small percentage of respondents. Is this demonstrative of a more widespread loss of interest in healthcare as a political talking point?

As someone whose day-to-day career is centered around health benefit plans, cost containment, and the attempt to ensure plan participants enjoy maximum care for minimal cost, understanding the rules and regulations that dictate and control what payers pay and providers of health care can and cannot do, is – for me – always top of mind. As an American, however, I cannot help but notice how little “airtime” healthcare seems to be getting during the ongoing presidential campaigns.  Compared to the 2020 and 2016 elections, during which healthcare was one of the top issues (including but not limited to the repeal and replacement of Obamacare), for the 2024 election it seems as if healthcare is an afterthought.

Recognizing that abortion, LGBTQIA+, and gun violence all relate to healthcare, and are certainly top issues during this presidential race, please note that when I suggest that “healthcare” isn’t the most pressing topic (compared to past elections), I am referring to general healthcare costs.

It would seem, based on the aforementioned KFF poll, that I am not far off. That poll revealed that for American voters, only 5% consider “healthcare costs” to be their top issue. When asked to specifically rank healthcare issues by importance to them, 21% to 24% of Democrats and Republicans (respectively) indicated that the cost of healthcare is the most pressing healthcare issue, followed by prescription drug costs (which 9% to 12% of respondents – Republicans and Democrats respectively – felt was the most urgent healthcare topic). 

Herein lies my concern. According to the same poll, four in ten voters stated that the economy and inflation is the most important issue. Yet, if healthcare costs are allowed to increase without checks and balances, it will impact individual and societal spending – thereby affecting the economy like nothing else.  Indeed, according to the Centers for Medicare and Medicaid Services (CMS), 17.3% of our nation’s spending is attributable to healthcare costs[2]. As a basis for comparison, various sources indicate that our national spending on the military ranges between 3.4% and 3.5%. 

This reveals the first misunderstanding on the part of the American voter. Specifically, that if you care about the economy, you must care about the cost of healthcare. As for the second misunderstanding on the part of the American voter, that would be understanding the difference between healthcare costs and premiums.

For many years, I have spoken at length about how people (and especially politicians) will refer to the “cost of healthcare” when in fact they are talking about premiums. Time and time again, a politician will claim to have “lowered the cost of healthcare” when they, in truth, only capped what an insurance carrier can charge in the way of premium. The actual price being charged by the provider of healthcare services (i.e., the doctor or hospital) hasn’t been addressed or reduced. The insurance carrier is merely being forced to pay a greater share of that cost without offsetting that cost onto their insureds in the form of higher premiums. This would seem to be a win for the premium-paying-populace – until they see an increase in co-pays, co-insurance, and deductibles – coupled with reduced benefits and coverage. As my grandmother used to say, “Nothing is free.  The money needs to come from somewhere!”

I have often assumed that the politicians mentioned above honestly don’t understand the difference between the cost of healthcare and the cost of health insurance. The KFF poll, however, has me wondering whether I may have been mistaken. In that poll, the same people who advised that – of healthcare topics “health costs” is far and away the most pressing issue (over 20%) – a mere 6% felt that “premium costs” are the most important healthcare topic. So – if 20% or more of my constituents want to hear that I am doing something about the cost of healthcare, but only 6% care to hear about my efforts to reduce health insurance premiums . . . and all I’ve done is reduce health insurance premiums . . . do I tell the truth and appease the 6%? Or do I equate health insurance premiums with the “cost of healthcare,” communicate that my reduction of health insurance premiums is actually a reduction of healthcare costs, and satisfy the 20%? The latter is the obvious, if disingenuous, answer.

The fact of the matter is that unless the actual cost of healthcare (that being the cost incurred by providers when they provide care, and the cost payers – both insurance and patients – pay when they receive care) is reduced, we will all pay that cost one way or another.  When I see, for instance, Vice President Harris’ campaign website celebrate a $35 “cap” on insulin prices, I am left wondering how many people realize that this doesn’t mean the insulin manufacturer is accepting a grand total of $35 for the insulin. Rather, patients’ out of pocket responsibility may in some instances be capped, and/or Medicare may be able to pay less, but the drug manufacturer is still going to be paid as much – or more – than they were receiving prior to the implementation of such a cap; even if it means charging commercial payers more to make up the difference. Commercial payers from whom many Americans receive their insurance (even those who were convinced to move to the ACA and State exchanges), and who – therefore – will pay the cost.

For those voters who say that the economy is the biggest issue, healthcare costs is a lesser issue, and premium costs are a smaller issue still . . . I wonder what they would say if I told them that these and so many other issues are actually different sides of the same coin?

The cost of healthcare may not be America’s hot topic anymore . . . but it likely should be.

Empowering Plans: P202 – Senator Sanders: “Stop ripping us off.”

On September 26, 2024

Attorneys Brady Bizarro and Andrew Silverio discuss the recent senate committee hearing on GLP-1 drug pricing and strategies that self-funded employers are using to manage the extreme costs of these drugs while we wait and hope for congressional action.

Click here to check out the podcast! (Make sure you subscribe to our YouTube and
Apple Podcasts Channels!)

 

The Phia Group Announces the Hiring of Justin Forton as a Client Success Account Executive

On September 19, 2024

CANTON, MA – September 19, 2024 – In its continued dedication to bolstering the health benefits industry, The Phia Group has hired Justin Forton as a Client Success Account Executive. Justin will channel his data analytics experience and industry-focused customer service expertise to support and collaborate with The Phia Group’s clientele.

“Client success requires more than generic e-mails and the occasional sales call,” remarked The Phia Group’s CEO, Adam V. Russo.  “Meaningful progress is made when an advocate dives deeply into statistics and analyzes present results to ensure current and future clients alike comprehend details and are provided with both a thorough understanding of the status quo as well as opportunities that exist if specific future steps are taken.”

The Phia Group’s Chief Revenue Officer, Jason Davis, commented, “Justin’s understanding of both data analytics and our industry’s needs, along with his passionate dedication to client service and advocacy, makes him the perfect fit for this role, and for The Phia Group.”   

Mr. Forton previously served as the Vice President - Analytics and Insights for Personify Health whereby he leveraged multiple data sources to build interactive custom dashboards, report on plan performance and operational metrics and other department input and output metrics in order to maintain operational excellence. Justin also served as Vice President Sales Operations at BAShealth, Vice President of Benefits at Full Service Insurance, Employee Benefits Consultant with Arthur J. Gallagher & Co., and Board Member for NAHU’s Middle Tennessee Association of Health Underwriters.

“I am honored to join The Phia Group!,” Justin exclaimed. “Their leadership and passion for their partners, clients, and staff is unmatched in the industry. The Phia Group was always our first call when we needed guidance and expertise to support our clients.  I look forward to being a part of the continued evolution and excellence that this team brings on a daily basis.”

To learn more about The Phia Group and how it empowers plans, please contact Garrick Hunt by email at [email protected] or by phone at 781-535-5644.

About The Phia Group: The Phia Group, LLC, headquartered in Canton, Massachusetts, is an experienced provider of health care cost containment techniques offering comprehensive claims recovery, plan document and consulting services designed to control health care costs and protect plan assets.  By providing industry leading consultation, plan drafting, subrogation and other cost containment solutions, The Phia Group is truly Empowering Plans.

The First Ten: Medicare Unveils Inaugural List of Negotiated Drug Prices

On September 16, 2024

By: David Ostrowsky

Last month, while many of us were busy vacationing or doing last-minute back-to-school shopping, the Biden administration announced that it had reached an agreement with the titans of the pharma industry to lower prices on the 10 costliest prescription drugs under Medicare, thus bringing to fruition Democrats' decades-long push to allow the government to negotiate directly with pharmaceutical manufacturers. While individual plans had previously been able to haggle over prices with Big Pharma, this development marks a seminal moment as it is the first time that Medicare used its clout to be able to negotiate for the program as a whole.

The ten commonly-used, high-cost drugs include: Eliquis, a blood thinner; Xarelto, a blood thinner; Januvia, a diabetes drug; Jardiance, a diabetes drug; Enbrel, a rheumatoid arthritis drug; Imbruvica, a drug for blood cancers; Farxiga, a drug for diabetes, heart failure and chronic kidney disease; Entresto, a heart failure drug; Stelara, a drug for psoriasis and Crohn’s disease; and Fiasp and NovoLog, diabetes drugs. And with the
discounts ranging from 79% for Januvia to 38% for Imbruvica, the cost savings promise to be immense. When the new prices go into effect in 2026, older Americans enrolled in Medicare Part D, many of whom are struggling mightily to afford life-changing prescriptions, are expected to save nearly $1.5 billion in out-of-pocket costs – which comes on the heels of realized savings from other provisions in the Inflation Reduction Act, including a $35 monthly cap on the out-of-pocket cost of insulin and an annual limit on out-of-pocket prescription drug costs; meanwhile, the current administration has estimated that taxpayers could reap $6 billion in savings.

“The negotiations were comprehensive. They were intense. It took both sides to reach a good deal,” Health and Human Services Secretary 
Xavier Becerra remarked about the contentious talks that culminated in the landmark deal.

While millions of seniors will eventually see costs of drugs that treat heart disease, cancer, and diabetes decline precipitously, the announcement was not universally lauded. Ever since the heated negotiations – as allowed by the Inflation Reduction Act – began in earnest this past January,
the pharmaceutical industry pushed back, filing several lawsuits to prevent the negotiated prices from going into effect while claiming the transition would stifle drug innovation. Furthermore, many Republicans denounced the Biden administration’s approach, opining that leveraging Medicare to “fix prices” would not only de-incentivize many pharma companies from investing in new therapies but also hamper competition. (It bears mentioning that the news was greeted with mostly apathy on Wall Street, as many financial analysts, noting how relatively few Americans pay the list prices for drugs anyways, predicted that the development would have a negligible impact on drug companies’ bottom line.) But, after back-and-forth negotiations in which Medicare ultimately accepted a drug company's counteroffer for nearly half of the other drugs while in the other cases companies consented to the government's written final offer, the Biden administration prevailed to achieve one of its landmark goals.


Though it may take many years to evaluate some of the aforementioned long-term concerns, there will be short-term ramifications in the coming months – well before the prices go into effect in 2026. As it stands, the federal government has until this coming March to publish explanations for how it reached the negotiated prices. If a prominent drugmaker such as Merck or Johnson & Johnson refuses to negotiate, it could face a tax penalty, which in turn could be lifted if the drugmaker opts to remove the drug from Medicare. Even before March, Medicare will start negotiating prices for the next batch of prescriptions with the process repeating annually. In fact, Centers for Medicare & Medicaid Services (CMS) can negotiate prices for another 15 drugs for 2027, an additional 15 in 2028, and then 20 medications per year starting in 2029 and beyond.

film izle