Quorum assists client with new regulations that pertain to PAPs under the Medicare Part D drug benefit
Business Challenge
The Medicare Part D drug benefit now provides prescription drug coverage to millions of Medicare beneficiaries. Prior to Part D, many of these same beneficiaries received assistance via manufacturer-sponsored patient assistance programs (PAPs) where they received medications free of charge. The Medicare Part D benefit changes the rules in how PAPs approached uninsured and under-insured patients as part of eligibility criteria.
Quorum’s client had been providing assistance to many Medicare beneficiaries prior to Part D. The client wanted to shift patients who could afford the medication to Part D; however, for patients who could not afford the medication under Part D, the manufacturer wanted to continue to provide assistance through the PAP. Providing free drug to this patient population was not as simple as before due to new guidelines from the Office of the Inspector General (OIG) regarding PAPs and Part D, which cautioned against providing “inducements” to Medicare beneficiaries under the Anti-Kickback Statute.
Our Approach
The situation required a delicate approach since the OIG guidelines recommended disenrolling patients from PAP who qualify for Part D. Meanwhile, patients who were signing up for Part D were not educated on the type of plan they were enrolling in, nor did they understand the impact of Part D on their PAP eligibility.
Our approach consisted of a legal review of the OIG guidelines and Medicare’s interpretation of providing assistance. In addition, we had to care for patients and their concerns for continued access to life-saving therapy.
Our Solution
We provided one-on-one counseling to PAP patients and research coverage benefits through their Part D plan. Quorum designed a new PAP process and eligibility criteria to allow for assistance to Medicare Part D beneficiaries who qualify for PAP. The re-tooling of the PAP process required new applications and correspondence, training for the client’s sales force, and alerting participating PAP providers. Another part of the solution required communication with each patient’s insurance plan which was not done prior to Part D.
Results Delivered
Providers and patients are satisfied with the enhancements to the PAP. The PAP has a reputation of providing quality information and superior customer service. Due to the enhancements in the PAP, we continue to meet the changing needs of these patients. As a result, patient enrollment in the PAP continues to grow at approximately 25 percent per year.
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