When I was inside Pharma managing the copay business we took a very skeptical eye toward Cash Card companies including Blink Health. After all, we worked tirelessly to provide programs that:
- Met OIG guidelines in terms of compliance
- Captured a limited set of self-reported patient information, meeting privacy policies for future safety, drug compliance, and marketing communication opportunities
- Were generally profitable
- Encouraged the appropriate use of Commercial insurance (we didn’t want the cards to supersede or interfere with insurance)
- Excluded patients in Government funded programs of all sorts
The problem with cash cards is that the math simply doesn’t make sense. Well I’ve never seen that being the case. Further, they take the market distorting aspect of coupons to another level – by blatantly making the point to payers that it’s better to go OUTSIDE of the insurance system for the provision of drugs. This can be a real problem from a number of levels, not the least of which is the times when Step Edits and Prior Authorizations are designed to protect patient safety. In these cases, ethical players should ACTIVELY take action to make sure that no patient assistance is given for very obvious reasons.
What happened in this case? We have no idea. Furthermore, we may never know. But knowing what I know about the inner working of ESI and what I’ve read about Blink Health – I’m going to write this blog and leave the conclusions up to you. Companies have contract disputes all the time. ESI has a multi-billion dollar business that’s 99%+ driven by contracting…
There are no magic bullets here. Harry, Ron, and Hermione aren’t going to fly in on broomsticks and solve the U.S. pricing system. (although how RAD would that be? I would pay to see that, and be sure to bring my kids along to double the fun). I would love to see the math at work for these Cash Card programs –they potentially help with certain fringe situations where they set the pharmacy price in a way that eventually helps the patient save money – think crazy Gx markups without a MAC for some reason.
In the meantime, I’d strongly recommend that Pharma stay away from the Cash Card end around game. After all, copay cards are here until at least 2023 – given all that we know from NCPDP. And we’ve reached a détente in the massive fight with commercial payers around allowing them. The next shoe is likely to drop in the second half of this year – I will write about that when it happens. But in the meantime, let’s not close our eyes and pretend that Cash Cards are the answer.
Learn about your programs and why they work and where they’re not working. If you need I’d be glad to help (rather self-serving but this IS a company BLOG). A well-designed program should have no need for augmentation with Cash Cards because:
- You lose control over patient attestation
- You lose/turn over the continuing customer communication to the Cash Card company
- You undermine the consistency of your brand messaging both in the field and importantly with managed care payers
- You increase the potential that access that you’ve obtained in Part D is ignored (also in Commercial, but I’m much more worried about Cards used in Part D at the moment)
- You potentially undermine your entire response to the OIG guidelines – if the regulators take the view that the REASON you engaged with a Cash Card company was to circumvent OIG requirements (and I would argue that this would be extremely hard to prove regardless of your internal justification as folks will take the most cynical view)
These are all serious problems for marketers.
I’m here to help. Your legal and compliance teams need commercial guidance from experienced professionals to construct and implement a company-wide response to the OIG. There’s very good reason to hire an external consultant who knows this space, as the guidance wasn’t to ‘be average’ it was ‘to be among the best’ in the industry. This isn’t Lake Wobegon.
PRO TIP: Contact your copay card vendor to make sure that your cards won’t/don’t process behind a Cash Card as primary. I know, I know. Strange things happen. I also know that a major player in this market was looking to CHARGE for this – should be included for free as part of a comprehensive OIG response/partnership agreement with vendors/partners/processors. You may be covered, or you may not. Better to be sure.