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American Benefits Council Comment Letter to HHS on Proposed Regs for Prescription Drug Rebates and Safe Harbors
American Benefits Council 
[Opinion] Apr. 9, 2019
11 pages. "As a general matter, employers do not support the current rebate structure as it is complex and opaque, hiding the true prices of drugs and the true value of how the rebate is calculated. The Council is concerned, however, that the Proposed Rule will not do enough to change the incentives for entities in the drug delivery chain that lead to higher list prices and larger rebates."
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