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Any referenced fulfillment or delivery metrics reflect internal pharmacy processing data for approved prescriptions only and do not guarantee timelines, approval rates, medication access, or outcomes, as actual fulfillment may vary based on provider review, pharmacy operations, regulatory requirements, patient responsiveness, shipping conditions, inventory, and applicable state or federal requirements

As stated in the CY 2025 PFS proposed rule (89 FR 61979), by structuring the Rebate Report process to include a Preliminary Rebate Report before the Rebate Report, CMS is able to provide manufacturers with an opportunity to review the Preliminary Rebate Report before the rebate amount is invoiced via the Rebate Report

The proposed mechanism involves preventing GABA receptor downregulation, counteracting compensatory NMDA receptor sensitization, and stabilizing benzodiazepine receptor configuration

Such an applicable percentage would, in effect, exclude drugs from the refund liability altogether, creating a significant loophole that undermines the goal of minimizing discarded amounts

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