Inflation Reduction Act: Part B rebatable drugs initial impact assessment

March 29, 2023

Impacted: Medicare

On March 15, 2023, the Centers for Medicare & Medicaid Services (CMS) released the first set of 27 Part B rebatable drugs with an adjusted coinsurance rate. Prime has completed our assessment of the impact for these first 27 drugs from 1/1/22 through 3/15/23. The following analysis was completed, and Prime has determined there is minimal impact to point-of-sale pharmacy claims for these 27 Part B drugs.

April ASP (Average Sales Price) File Impact Analysis Steps:
Prime took the following steps to identify any potential impacted NDCs (National Drug Code) based on historical claims.

  1. Prime used the CMS Announcement to identify the 27 HCPC codes CMS indicated would have inflationary rebates adjusted coinsurance.
  2. Using HCPCs identified in Step 1, Prime identified NDCs attached to those HCPCS using the CMS ASP HCPCS to NDC Crosswalk.
    1. Please note: 4 HCPCs from the CMS Announcement were not listed in Crosswalk: J0699, J0135, J2265 and J2502. This is because these 4 Part B products were included in the April Outpatient Prospective Payment System (OPPS) Addendum Public File.
  3. Prime ran a claims report from 1/1/22-3/15/23 to look for GPIs (Generic Product Identifier) (from the 4 HCPCS not on the crosswalk) and the NDCs from the crosswalk.
  4. For the date range of 1/1/22-3/15/22, Prime identified two claims for one client from 2022 that had an NDC for a paid claim that matched to what was in the crosswalk. No claims were identified as impacted for 2023.
    1. Please Note: The impacted client received a separate communication with the details for these two claims. ​​​

Next Steps: 
Prime is investigating options for ongoing reporting to determine the best approach to communicate impact to clients until the system enhancement allows us to apply the lower coinsurance at the point-of-sale in December 2023.

Please contact your Client Engagement representative or the Regulatory Change Management (RCM) team ( with any questions.