New OIG Guidance on PAP Programs

The Office of the Inspector General has released a supplemental bulletin alerting pharmaceutical manufacturers that third-party Patient Assistance Programs (PAPs) that are run by independent charities might be subject to prosecution under fraud and anti-kickback statutes.

Quoting from the press release on the OIG website:

"OIG is mindful of the importance of helping financially needy beneficiaries of Federal programs receive needed medical care. Independent charities can play an important role in advancing this goal. If, however, a charity acts as a conduit for a drug manufacturer to induce the prescription of its drugs, Federal health care programs and their beneficiaries are put at risk. OIG will therefore closely scrutinize PAPs that do not appear sufficiently independent from their donors," said Inspector General Daniel R. Levinson.  

You can read the full release and access the bulletin from these links:
http://oig.hhs.gov/newsroom/news-releases/2014/charity.asp
http://oig.hhs.gov/fraud/docs/alertsandbulletins/2014/independent-charity-bulletin.pdf