News & Analysis as of

Free-Drug Programs

Bass, Berry & Sims PLC

OIG Approves Free Drug Program for Ultra-Rare Condition in Advisory Opinion 23-02

Bass, Berry & Sims PLC on

On February 23, the Office of Inspector General (OIG) of the U.S. Department of Health and Human Services issued Advisory Opinion 23-02, approving a pharmaceutical company’s program to provide a free 14-day supply of an...more

Bass, Berry & Sims PLC

OIG Approves a Free Drug Program Limited to Hospital Inpatients

Bass, Berry & Sims PLC on

On November 16, the Office of Inspector General for the U.S. Department of Health and Human Services (OIG) published Advisory Opinion 21-16, approving an arrangement under which a pharmaceutical manufacturer provides free...more

McDermott Will & Emery

OIG Dusts off the Old Rule Book to Say No to Free Expensive Drugs to Hospitals

McDermott Will & Emery on

The Office of Inspector General, Department of Health and Human Services posted an unusual negative Advisory Opinion (AO 18-14) on a drug company’s proposal to provide free drugs to hospitals for use with pediatric patients...more

Holland & Knight LLP

OIG Considers Drug Pricing History in an Unfavorable Advisory Opinion on Free Drugs

Holland & Knight LLP on

• The OIG issued an unfavorable advisory opinion on a proposed program by which a marketer would provide free drugs to hospitals to utilize in an inpatient setting to treat infantile epilepsy. • Contrary to the typical...more

Holland & Knight LLP

OIG Issues Letter Declining to Impose Administrative Sanctions for Provision of Certain Free Drugs

Holland & Knight LLP on

On Jan. 4, 2018, the HHS Office of Inspector General (OIG) issued an open letter containing guidance regarding the provision of certain free drugs to federal healthcare program beneficiaries. Specifically, the OIG stated that...more

Holland & Knight LLP

OIG Rescinds Advisory Opinion

Holland & Knight LLP on

The Department of Health and Human Services Office of Inspector General (the OIG), on November 28, 2017, issued a Rescission Letter terminating Advisory Opinion Number 06-04 (Advisory Opinion 06-04). In Advisory Opinion...more

King & Spalding

OIG Issues Guidance Related to Free and Discounted Prescription Drugs Provided to Patients

King & Spalding on

HHS Office of Inspector General (OIG) recently clarified its guidance related to the provision of free or discounted prescription drugs in two contexts: (1) hospital discounts or waivers of self-administered drugs in...more

Baker Donelson

OIG Approves Limited, Free Drug Program

Baker Donelson on

On August 12, 2015, the Department of Health and Human Services, Office of Inspector General (OIG) issued Advisory Opinion 15-11, approving two pharmaceutical manufacturers’ free starter drug program. Citing the limited scope...more

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