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
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.