Unique in its scope, benefit design and financing arrangements, the newly launched Medicare Part D benefit has, virtually overnight, transformed the federal government's exposure to the cost of pharmaceutical therapies. Accordingly, as the HHS Office of Inspector General, CMS and the Department of Justice have repeatedly broadcast, Part D has become fertile territory for anti-fraud scrutiny and enforcement. Six months into the brave new world of Medicare Part D, this teleconference addresses its implications for pharmaceutical company relationships with both patients and providers, with a focus on the following:
• Patient Assistance Programs – including both manufacturer-sponsored and independent, charitable PAPs.
• Retail-level rebate programs, such as those offered to long-term care pharmacy operators.
• Coupons, trial-scripts and other direct-to-consumer discount programs.
The teleconference will describe the evolving state of regulatory guidance on these arrangements; assess conflicting forces in the political climate that favor curtailing or expanding them; and, given the continuing uncertainty, conclude with practical tips for minimizing implementation risk.
Ropes & Gray Speakers
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