Reassessing Protected Classes: The Impact on Part D Formularies

Richard P. Kusserow | August 2009

This article focuses on an interim rule issued by the Centers for Medicare & Medicaid Services (CMS) on the process CMS will follow to designate protected classes and categories of drugs using a two-pronged test and to implement the redefinition of “medically acceptable indication” under Part D.

About the Author

Richard P. Kusserow established Strategic Management Services, LLC, after retiring from being the DHHS Inspector General, and has assisted over 3,000 health care organizations and entities in developing, implementing and assessing compliance programs.