Important Information concerning Q2 2016 Invoices

Some manufacturers may have Q2 invoice amounts that are higher than expected due to Part D sponsors resubmitting PDEs with gap discount amounts as a result of a system update to the logic for edit code 870, which was described in our April 11, 2016 Health Plan Management System memorandum. In addition, there was a significant increase in PDEs that were previously withheld through the CMS outlier review process that were corrected and resubmitted in time for the Q2 invoices. Both issues may result in higher than usual invoices for certain manufacturers.