BRG Report on CMS May 2024 Draft Guidance

The Centers for Medicare and Medicaid Services (CMS) released updated draft guidance on May 3, 2024, incorporating significant new details regarding the role of the Medicare Transaction Facilitator (MTF) and expectations for manufacturers.

In this report, we highlight important takeaways as manufacturers continue to explore options for effectuation of the maximum fair price (MFP) and nonduplication with the 340B channel.