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What other features should CMS consider in designing financial benchmarks that balance prospectivity and accuracy, and that can lead to savings for both ACOs and Medicare

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To calculate the reduced total rebate amount for a Part D rebatable drug, in 428.301(b)(1), CMS proposes the following formula: Reduced Total Rebate Amount = the total rebate amount multiplied by (1 minus applicable percent reduction) multiplied by (percentage of time drug was currently in shortage during the applicable period) added to the total rebate amount multiplied by (1 minus percentage of time drug was currently in shortage during the applicable period) For the purpose of this formula, for a Part D rebatable drug that is a generic drug or a plasma-derived product, in 428.301(b)(2)(i), CMS proposes an applicable percent reduction of 75 percent for the first applicable period such Part D rebatable drug is currently in shortage, 50 percent for the second applicable period, and 25 percent for each subsequent applicable period

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