American Healthcare Choices | On Rebate Rules and Expenditure Estimates

Last week the Trump Administration rolled out a semiannual summation of all the administration’s regulatory activity. Noteworthy for health policy observers, the administration has pushed back to November finalization of the proposed rule on manufacturer rebates for drugs purchased through the Medicare Part D and Medicaid Managed Care program. Opposition to the proposed rule has focused on the potential increase in costs to the federal government. It is important, however, to recognize just how uncertain the myriad cost analyses of this proposed rule are. AAF recently reviewed six cost estimates in detail here, but the key takeaway is that the numbers produced by these estimates depend greatly on behavioral responses that are enormously hard to predict correctly.