Manufacturer coupons may not be used by beneficiaries of Federal health care programs, but recent surveys found that 6 to 7 percent of seniors reported using manufacturer coupons towards Part D drug copayments. This means that over 2 million beneficiaries could be using copayment coupons for prescriptions paid for by Part D.
The OIG investigated whether pharmaceutical manufacturers employed sufficient safeguards to prevent Part D beneficiaries from using copayment coupons. All surveyed manufacturers provided notices to beneficiaries and pharmacists on at least one of their coupon formats, and most implemented pharmacy claims edits to prevent the coupons from being processed with Part D claims. However, the OIG found notices that were printed in small font and/or provided on separate pages, so they may not be seen by beneficiaries or pharmacists. Furthermore, the surveyed pharmacy claims edits may not accurately identify Part D beneficiaries. For example, some manufacturers based the edit on the beneficiary’s age, which would ignore beneficiaries under 65 who qualify for Part D due to a disability and flag beneficiaries who are over 65 but are not enrolled in Part D. Unfortunately, because it is very difficult to identify the use of copayment coupons within pharmacy claims, Part D plans and oversight entities cannot reliably prevent the use of manufacturer coupons.
The OIG released a Special Advisory Bulletin reminding pharmaceutical manufacturers of their responsibility to distribute coupons in compliance with Federal law. The OIG also recommended that CMS work towards improving the reliability of pharmacy claims edits that prevent the use of copayment coupons, increasing coupon transparency, and making the use of coupons identifiable in pharmacy claims.