How current Part D risk scores could interact with point-of-sale rebates: Recalibration of RxHCCs for POS rebates could have disparate impacts on plan sponsors

On November 20, 2020, the U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) finalized a proposal to lower prescription drug costs by removing the safe harbor protection of drug manufacturer rebates under the Anti-Kickback Statute (AKS), creating a new safe harbor for price reductions reflected at the point of sale (POS). In this paper, we focus on the implications of potential changes to the Part D risk score mechanisms. Recalibration of prescription drug hierarchical condition categories (RxHCCs) for POS rebates could have disparate impacts on plan sponsors.