OIG Report and Special Advisory Bulletin Identify Vulnerabilities in Copay Coupon Processing

On 19 September 2014 the Office of Inspector General for the U.S. Department of Health and Human Services (OIG) released a report reviewing the effectiveness of safeguards that pharmaceutical manufacturers have in place to ensure that Medicare Part D beneficiaries do not use copay coupons. In conjunction with the report, the OIG also issued a Special Advisory Bulletin (SAB) that reiterates the legal risks presented by copay coupons under the federal Anti-Kickback Statute (AKS) insofar as they induce a beneficiary to purchase a drug reimbursable under a federal healthcare program, like Medicare Part D. This alert discusses OIG’s finding and the implications for coupon programs.

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