Scott Dulitz

The Challenge of Providing Patient Assistance Under the ACA

There’s a lot of ambiguity around how the government is going to view the private and public exchanges. An OIG opinion providing guidance on whether these plans will be viewed as public versus private plans could have far-reaching implications for how manufacturers provide patient assistance. If we look at some of the OIG guidance offered around Medicare Part D plans and the potential for anti-kickback penalties when offering direct assistance to these beneficiaries, we can start to hypothesize about some of the challenges pharmaceutical manufacturers will face.

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