Do safety-net pharmacy reductions count towards TrOOP?

Our research indicates that only safety-net pharmacies that do not receive or use government/public funds can be counted towards TrOOP.  Unfortunately, in most cases, safety-net pharmacies do receiv and utilize some form of public or government funding. 

From CMS' document ID 7793 in the CMS FAQ dated 8/17/06, "Safety-net pharmacies typically include Federal, State, and locally supported community health centers (CHCs) or clinics, any of which are deemed Federally Qualified Health Centers (FQHCs), public hospital systems, and local health departments...However, we clarify that, to the extent that the party paying for cost-sharing on behalf of a Part D enrollee is a group health plan, insurance, government funded health program, or party to a third party payment arrangement with an obligation to pay for covered Part D drugs, that party's payment will not count towards TrOOP. Thus, payments made for beneficiary cost sharing by any entity - including safety-net pharmacy - that has an obligation to pay for covered Part D drugs on behalf of Part D enrollees, or which voluntarily elects to use public funds, in whole or in part, for that purpose, will not count towards that beneficiary's TrOOP expenditures." 

Additionally, where government funded safety-net pharmacies waive or reduce cost sharing, those costs are not added to TrOOP. Furthermore, safety-net pharmacies are not Part D contractees, and therefore are not required to track administrative costs such as TrOOP. 

(Back to Questions about Cost-Sharing)