The Food Marketing Institute (FMI) appreciates the opportunity to comment on the Centers for Medicare and Medicaid Services (CMS) final rule to implement provisions of the Deficit Reduction Act (DRA) related to prescription drugs reimbursed under the Medicaid Program (“Final Rule”). As we stated in our response to the proposed rule, FMI is very concerned about the impact of the rule on its supermarket pharmacy members. We are heartened that CMS made some positive changes to the rule in response to comments, but we believe that much improvement is still needed to avoid serious problems for the Medicaid program. Our comments and further recommendations are discussed more fully below.

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