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2006 proposed fee schedule - American Society of Clinical Oncology

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customers (for example, physicians) via a wholesaler (or<br />

237<br />

distributor). Wholesaler chargeback arrangements may vary<br />

in scope and complexity. However, simply put, the<br />

wholesaler administers contract prices negotiated between<br />

the manufacturer and end purchasers (for example, physician<br />

or other health care providers), or otherwise implements<br />

pricing terms established by the manufacturer (for example,<br />

pricing that varies by type <strong>of</strong> purchaser or class <strong>of</strong> trade).<br />

The wholesaler charges the customer a certain price and<br />

charges back the manufacturer an agreed upon amount for the<br />

purposes <strong>of</strong> making up the difference between the<br />

wholesaler’s price (for example, WAC) and the customer’s<br />

price.<br />

Under the current estimation methodology for lagged<br />

price concessions, total lagged price concessions, including<br />

lagged wholesaler chargebacks, for the 12-month period are<br />

divided by total sales for that same period to determine a<br />

ratio that is applied to the total sales for the reporting<br />

period. The ratio <strong>of</strong> lagged price concessions to sales is<br />

calculated over all sales, both indirect sales (sales to<br />

wholesalers and distributors and other similar entities that<br />

sells to others in the distribution chain) and direct sales<br />

(sales directly from manufacturer to providers, such as<br />

hospitals or HMOs). To the extent that the relationship<br />

between total dollars for indirect sales and total dollars

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