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We also proposed new policies for the Medicare Part D Drug Inflation Rebate Program as follows: Proposed to use a claims-based methodology to implement 428.203(b)(2), which provides that, for claims with dates of service on or after January 1, 2026, and for an applicable period, CMS will exclude from the total number of units used to calculate the total rebate amount for a Part D rebatable drug those units of the Part D rebatable drug for which a manufacturer provided a discount under the 340B Program

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This research was funded by the US Department of Veterans Affairs (to Z.A.A.)