Prior Quarter Adjustment Statement

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.