Case Study: CHAMP Success Story
March 6, 2026From Policy to Practice: Delivering Measurable Impact Through the CMS Discarded Drug Program
Delivering Medicare Part B discarded drug refunds through analytics-driven execution, validation, and outreach
Overview
Annual Medicare Part B drug claims processed in 2025 totaled over $81 billion, nearly tripling the $39 billion spent in 2019. Accuracy in determining Medicare Part B drug payment limits is critical, as Medicare Part B Average Sales Price (ASP) pricing data serves as the foundation for an estimated $3.5 billion in savings under the Consolidated Appropriations Act (CAA), a projected $56.3 billion in drug rebate and negotiation savings, and $3 billion in refunds from discarded drugs by 2034.
The Centers for Medicare & Medicaid Services (CMS) implemented the Discarded Drug Program (DDP) in 2024 to calculate discarded drug refund amounts due, publish Discarded Drug Refund Reports, and collect refund payments from manufacturers for certain discarded amounts from a refundable single-dose container or single-use package drug (hereinafter referred to as a refundable drug). In the first year, CMS issued Discarded Drug Refund Reports for manufacturers resulting in $139 million in refunds due to the government.
Index's Approach
Index Analytics (Index) was instrumental in assisting CMS with launching the first year of the Discarded Drug Program by cultivating deep subject expertise on the relevant policy, building a robust analytics model, streamlining validation of eligibility and refund calculations, and executing a comprehensive communications strategy to educate the program’s key stakeholders.
Refundable Drug Eligibility
Accurate Drug Refunds
Applied Legislative Requirements
Website content
Factsheets, reference guides, & worksheets
X (formerly Twitter) posts
CMS ASP eNewsletter
Email campaigns
CMS Webinar Session with real-time Q&A
Program Year 2 Complexity
In the second year of the Discarded Drug Program, Index advanced its foundational strategy to meet new challenges and deliver impactful results:
- Adapted to increased complexity and tighter timelines by integrating two years of claims data, updating calendar year (CY) 2023 refund amounts based on lagged claims, and recalculating refund obligations by factoring in previously paid amounts.
- Enhanced the data analytics model to incorporate lagged CY 2023 claims and new CY 2024 submissions, ensuring accurate and compliant refund adjustments.
- Delivered $173 million in refunds for Year 2, with reports released on September 1, 2025.
- Supported validation of revised calculations and improved the user interface for report publication and payment processing.
- Led targeted outreach and education efforts, including training and refining materials to help manufacturers navigate Year 2 changes.
Conclusion
Index’s success in the Discarded Drug Program stemmed from assembling a policy-savvy team, building a powerful analytics model, validating eligibility, and executing a strategic communications plan. These efforts led to $139 million in refunds in Year 1 and positioned the organization to meet CMS’s evolving needs. In Year 2, Index supported the generation of more complex refund reports—published on September 1, 2025—totaling over $173 million.
Disclaimer: This communication does not represent the official views, policies, or positions of the Centers for Medicare & Medicaid Services (CMS) or the U.S. Department of Health and Human Services (HHS). References to CMS programs, systems, or activities are provided for informational purposes only and do not constitute endorsement, sponsorship, or approval by CMS or HHS of any products, services, vendors, or organizations mentioned. Any performance metrics, cost figures, or outcomes described are the responsibility of the authors and have not been independently validated by CMS.