I am starting a series of posts consisting of mini-topics that I covered during my December webinar. I had many questions regarding the information presented and will try to address some of the issues in this series.
Today I will be talking about manufacturer coupons, which is a common cause of significant PBM recoupments.
Let’s review when a pharmacy can safely apply manufacturer coupons. According to PBM manuals, coupons may be applied when a pharmacy:
- complies with the pharmaceutical coupon program. For example, all such programs exempt government-sponsored plans.
- does not apply coupons on any compounds, medical devices or medical foods. Sounds straightforward? Often, however, pharmacies fail to spot these products. For example, one of the cases I had last year involved a scar gel, which the FDA classifies as class 1 medical device. As a result, a PBM recouped 100% of what it paid to the pharmacy for dispensing these expensive gels.
- does not apply coupons on products not subject to the FDA approval process, such as multivitamins and supplements.
- does not apply coupons to non-FDA approved drugs. In my experience, this is the most common PBM issue relating to inappropriately applied coupons. The easiest way to verify if the drug is FDA approved is to consult the Orange Book.
Some PBMs also exclude coupons from specific programs or associations. Make sure to review your manuals to ensure compliance with each specific PBM requirement.
Related Blog Post: “When applying manufacturers coupons could get a pharmacy in trouble.”