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
- How do manufacturer-issued coupons for these high-cost
- 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
- 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?