Drug Manufacturers Must Reform Marketing to Avoid Hurting
Current practice of copay coupon damages Medicare Part D, can make
Sept. 22, 2014 In response to the warning
for senior citizens not to
use brand name drug discount coupons in the Medicare Part D program, the
president of the association for pharmacy benefit managers said the
pharmacy manufacturers must assure regulators that copay coupons don't
induce demand for brand drugs and increase costs in public programs like
The special advisory by the Department of Health and Human Services
Office of the Inspector General (OIG) issued last week said "copay
coupons," a drug manufacturer marketing tactic often used to inflate
sales of brand drugs among patients with prescription drug coverage, may
now be infiltrating Medicare Part D.
Federal anti-kickback laws prohibit suppliers from
offering side-payments to increase sales of goods that are subsidized by
the federal government.
The report highlights that two recent surveys, including one by the
Pharmaceutical Care Management Association (PCMA), found that
approximately 6 to 7 percent of seniors in Part D reported using coupons
to purchase prescription drugs.
According to the OIG report, "manufacturers may be liable under the
anti-kickback statute if they offer coupons to induce the purchase of
drugs paid for by Federal health care programs, including Medicare Part
The report notes that "coupons may increase costs for Part D plans
because they may encourage the purchase of more expensive brand-name
drugs instead of less expensive alternative treatments, such as generic
drugs." One study indicated that copay coupons
could increase costs
in Medicare by $18 billion.
"Drug companies must develop robust marketing safeguards to assure
regulators that copay coupons don't induce demand for brand drugs and
increase costs in public programs like Medicare. Manufacturers would do
more good by focusing on the millions of uninsured Americans who must
bear the full cost of drugs, not merely the copay," said PCMA President
and CEO Mark Merritt.
>> Pharmaceutical manufacturers' current safeguards may not prevent all
copayment coupons from being used for drugs paid for by Part D.
>> Most surveyed manufacturers use pharmacy claims edits to prevent
coupons from being processed for drugs covered by Part D. Most of these
edits may not prevent all coupons from being processed for Part
Part D plans and other entities cannot identify coupons within pharmacy
>> The Centers for Medicare and Medicaid Services (CMS) should cooperate
with industry stakeholder efforts to improve the reliability of pharmacy
claims edits and make coupons transparent.
PCMA represents the nation's pharmacy benefit managers (PBMs), which
improve affordability and quality of care through the use of electronic
prescribing (e-prescribing), generic alternatives, mail-service
pharmacies, and other innovative tools for 216 million Americans.
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