Once a manufacturer has received an invoice, payment is due to HHSC within 38 days from receipt of the invoice, to avoid incurring interest. Two CMS forms are required when submitting payment or disputing an invoice:

• Reconciliation of State Invoice (Form CMS-304)
• Prior Quarter Adjustment Statement (Form CMS-304a)

Both forms are submitted with payment to identify where the payment is applied in the rebate system. Refer to the Rebate Administration forms for copies of the forms.

Manufactures submitting a check for payment of their current invoice must include a ROSI documenting the invoice, program, and amounts to be applied. A PQAS should also accompany the payment when the prior quarter is paid.

Once received, check amounts are allocated at the NDC 11-digit level by the drug rebate system. If the check is not fully allocated then the rebate system lists the line items in dispute. Next, an extract from the rebate system is pulled containing claim details for disputed NDCs and automatically provided to the manufacturer. It is the manufacturer’s responsibility to review the claim detail extract and provide any additional information to resolve the dispute. When resolving disputes, the manufacturer must:

• Contact CMS to correct any discrepancies in the URA submitted to CMS;
• Correct the ROSI or PQAS form and resubmit it to the VDP rebate administrator if there are any discrepancies in the URA

Discrepancies regarding units dispensed are resolved on a case-by-case basis by VDP in collaboration with the manufacturer. Contact the VDP rebate administrator for questions about dispute resolution.

Use the PQAS to uniformly explain prior quarter payments or disputes. The PQAS may accompany the ROSI or submitted separately.  Submit both forms with rebate payments or payment adjustments for all prior quarters.

The PQAS is used for reporting all prior quarter actions, including invoiced unit changes, prior disputed unit adjustments, and other information. Complete a separate quarter-specific PQAS for each prior quarter reconciled and submit the completed PQAS with the payment/credit for all prior quarters.

If the manufacturer completes and submits the PQAS with the ROSI, the amount of the remittance must equal the total remittance shown on the ROSI, plus or minus the total remittance on the PQAS. An explanation of any interest payment must accompany the submission.

A PQAS is submitted in the required format, in paper form or electronically, depending on the manufacturer’s capabilities. No additional information is entered on the form itself and all information must be included unless instructed in the data definitions found on the form.

Payment packages received from a manufacturer are allocated to the respective 11digit NDCs invoiced for all rebate programs. Invoices are compared to the ROSI and/or PQAS forms returned by the manufacturer with the payment to identify which NDC 11-digit line items are different from the invoice or are in dispute.

The Medicaid Drug Rebate Data Guide for Manufacturers has complete instructions for ROSI and PQAS submittal and reporting requirements for manufacturers participating in the CMS MDRP.  

The guide is part of the DDR for Medicaid System and accessible after registering with CMS and signing an NDRA. Contact CMS at DRP@cms.hhs.gov for access to the DDR system or questions about the ROSI or PQAS forms.

Refer to the Manufacturer Payments section for contact information. Payments must include the invoice number, as indicated on the invoice.

Use the ROSI to respond to Texas when: 

• Disputing invoiced units
• State invoice contains zero URAs
• Documenting invoice(s), program(s) and amount(s) to be paid, even if the state invoice contains zero URAs

Manufacturers must remit accurate rebate payments, and the current URA must be applied to the units paid.