The Office of Inspector General (OIG) and Centers for Medicare and Medicaid Services (CMS) have established their guidance concerning the integration of PAP programs and the Part D prescription benefit.
- OIG Statement: Special Advisory Bulletin on PAP's [PDF]
- Advisory Opinion 07-06 [PDF] - concerning the management by a health care industry consultancy of a charitable organization's arrangement to subsidize patient cost-sharing and premium obligations
- Advisory Opinion 07-04 [PDF] - concerning a pharmaceutical company's patient assistance programs, which will provide free outpatient prescription drugs to financially-needy Medicare Part D enrollees entirely outside of the Part D benefit
- Advisory Opinion 06-21 [PDF] - concerning a pharmaceutical company's patient assistance programs, which will provide free outpatient prescription drugs to financially-needy Medicare Part D enrollees entirely outside of the Part D benefit
- Advisory Opinion 06-19 [PDF] - concerning a pharmaceutical company's patient assistance programs, which will provide free outpatient prescription drugs to financially-needy Medicare Part D enrollees entirely outside of the Part D benefit
- Advisory Opinion 06-14 [PDF] - concerning a pharmaceutical company's patient assistance programs, which will provide free outpatient prescription drugs to financially-needy Medicare Part D enrollees entirely outside of the Part D benefit
- Advisory Opinion 06-13 [PDF] - concerning a nonprofit, tax-exempt, charitable organization's practice of providing financially needy persons who have [diseases redacted] with grants to defray the costs of premiums and cost-sharing obligations under Medicare Part B, Medicare Part D, Medicare Supplementary Health Insurance, and Medicare Advantage
- Advisory Opinion 06-10 [PDF] - concerning a nonprofit, tax-exempt, charitable organization's practice of providing certain therapy management services and assistance with Medicare cost-sharing obligations to financially needy Medicare beneficiaries undergoing medical treatment for certain diseases
- OIG Advisory Opinion 06-09 [PDF] - concerning a nonprofit, tax-exempt, charitable organization's proposals to subsidize Medicare Part D premium and cost-sharing obligations owed by financially needy patients with end-stage renal disease and chronic kidney disease
- OIG Advisory Opinion 06-08 [PDF] - concerning a free clinic's practice of dispensing drugs on behalf of patient assistance programs ("PAPs") sponsored by pharmaceutical manufacturers that provide free drugs to financially-needy patients, including some patients enrolled in the Medicare Part D outpatient prescription drug benefit
- OIG Advisory Opinion 06-04 [PDF] - concerning a nonprofit, tax-exempt, charitable corporation's proposal to provide financially needy Medicare beneficiaries with assistance with premiums and cost-sharing obligations under Medicare Part B, Medicare Part D, Medigap [as hereinafter defined], and Medicare Advantage
- OIG Advisory Opinion 06-03 [PDF] - concerning a pharmaceutical company patient assistance program that provides free outpatient prescription drugs to financially-needy Medicare Part D enrollees entirely outside of the Part D benefit
Patient Assistance Programs and Part D: Updates on Industry News
There have been a number of recent news items concerning PAP's, Part D, industry, and the OIG interpretation that was released last year. Below are a few of documents that will give you an overview of the latest news and some of the earlier CMS and OIG documents.