Nov 16, 2020

Prescription drug costs, particularly for specialty drugs, pose a significant financial threat to employer group health plans. But what if those group plans could “clip” manufacturer coupons given to plan members to reduce the plan’s payment?  A new solution, drug coupon maximization programs, can generate enormous prescription drug savings for a plan, but they can also create some ERISA compliance issues.

Scott and Ed are joined by Mark Holloway, JD, of Lockton Compliance Services, and Julayana Meyer, of Lockton Dunning’s pharmacy analytics team, to explore the evolving opportunities, mechanics and potential compliance issues of these programs.

• What are specialty medications? How much do they cost an employer group plan? (Hint: more than a cruise missile, according to Ed.)
• How do manufacturer-issued coupons for these high-cost medications work?
• What is a drug coupon maximization program? How can it help the employer save on its drug spend if the consumer is the one getting the discount? Can Scott calculate the savings in his head? (Spoiler alert: No.)
• Are these programs legal under ERISA? Does the coupon value have to be applied to the member’s out-of-pocket maximum? (Psssst … Scott had our backs on this one.)
• Does a drug manufacturer’s coupon amount to prescription coverage, or is it more akin to a drug discount card, and what does that matter for HSA-compatible plans?
• Do prescription drug coupon maximization program vendors guarantee the programs are copacetic?