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Pharmaceutical Manufacturers Rebilling of 3QCY2009 through 4QCY2011

Rebilling of 3QCY2009 through 4QCY2011

The government will be sending out revised/corrected billings for the period July 1, 2009 through December 31, 2011.

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Q1:

Why are new billings being processed? (Published January 2013)

A:

Due to enhancements in the Retail Refund Calculation process and improvements in communication of eligible products among manufacturers, the VA, and DoD, utilization data/refund recalculations are being performed to ensure accuracy of the data reported to manufacturers, as well as refunds due to DoD, since the inception of the Final Rule.

Q3:

Are there changes to how this debt will be calculated (packages to units or units to packages)? What are they and why? (Published January 2013)

A:

Recalculations for 3QCY2009 through 4QCY2011 are based on the refund calculation method (unit vs. FCP Package Size) selected by the manufacturer on their DoD Retail Refunds Pricing Agreement. If no method is selected, the calculation method will default to FCP Package Size.

Q4:

If the original billing was overstated and we paid it, what happens to our overpayment? How do we get these dollars refunded to us? (Published January 2013)

A:

Based on prior payments received, if an overpayment exists, the Defense Health Agency (DHA) will not issue a refund of any overage balances. The DHA will be applying additional monies received over and above the original calculations to NDCs that still have outstanding balances. The additional amount of the overpayment will be held until future communication is received from the Pharmaceutical Manufacturer. Please contact your DHA assigned Financial Manager in Aurora to coordinate the applying of these funds to any outstanding balances in subsequent quarters.

Q5:

What about the disputes we've already filed on the original amount billed? (Published January 2013)

A:

A refund obligation as to the amount in dispute will be deferred pending good faith efforts to resolve the dispute. When the dispute is resolved, any refund owed to the amount in dispute will be subject to interest, penalties and fees from the date payment of the amount was initially due, consistent with 199.11. See 32 C.F. R 199.21(q)(3)(iv).

Q6:

What happened to our waiver/compromise request? (Published January 2013)

A:

Waiver/compromise requests for 3QCY2009 through 4QCY2009 refund debt remain pending and will be resolved on a future date.

DHA Address: 7700 Arlington Boulevard | Suite 5101 | Falls Church, VA | 22042-5101

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