Lexology February 18, 2025
In honor of Rare Disease Day on February 28, 2025, we will publish a series of posts throughout the month on As Prescribed and Health Law Scan, focusing on issues impacting the rare disease community.
Patient assistance programs (PAPs) emerged to help patients who lack health insurance or prescription drug coverage obtain critical, and often, life-saving medications. This is especially true for rare disease patients, whose medications are typically costly, such that even affording copay or coinsurance payments can be a prohibitive challenge. However, for various reasons, PAPs have come under intense scrutiny from the US Department of Health and Human Services Office of Inspector General (HHS OIG) under theories that the subject programs run afoul of, among others, the...