PHARMACY LAWS, MEDICARE, MEDICAID AND BUSINESS MANAGEMENT

1. A misbranding refers to label that is false, and misleading, and in other words does not reflect the
true contents of the container to which labels are affixed. Examples are prescription written for
Adalat but filled for Procardia, an original bottle labeled 50 tabs contains only 60 tablets and names
of active/inactive ingredients are missing.
2. If a prescription bottle has an expiry date of July 08, it means the pharmacist can dispense until
July 31.
3. Drug references are required for retail or outpatient pharmacy and must be current. Following
references are required USP, NF, pharmacology, drug interactions, and Michigan OR ANY STATE
LAW pharmacy laws and public health codes.
4. Adulteration refers to the composition of a product. A drug is adulterated if it contains in whole or
in part of any filthy, putrid or decomposed substance, if is prepared or packed under unsanitary
conditions, if does not fall under GMPs or becomes contaminated. Examples are an herbal product
which contains American ginseng rather than the Chinese ginseng listed on the label, a product on
the shelf for the sale is past its expiration date, sterile parenteral solution contains a few
microorganisms, assay or purity is lower than that listed on the lable and active/inactive
ingredients have gone partial decomposition.
5. All dispensed prescription medication containers are required to bear a label containing at a
minimum of pharmacy name and address, Rx number, patients name, the date Rx was most
recent dispensed, prescribers name, direction for use, any cautionary statement and the name of
medication. The Rx must also bear discard this medication one year after the date it is dispensed.
All labeling of Rx drugs shall comply with the requirement of the code of federal FD and C Act.
6. All dispensed prescription medication containers are required to bear a label containing at a
minimum of pharmacy name and address, Rx number, patients name, the date Rx was most
recent dispensed, prescribers name, direction for use, any cautionary statement and the name of
medication. The Rx must also bear discard this medication one year after the date it is dispensed.
All labeling of Rx drugs shall comply with the requirement of the code of federal FD and C Act.
7. In addition to the manufacturers original label on OTC drugs, which cannot be defaced or altered
or covered, the pharmacist or pharmacy intern shall affix name of dispenser, the name and address
of pharmacy on OTC products.
8. FDA labeling requirement for OTC drugs are active ingredient, purpose, uses, directions, inactive
ingredients, lot number and expiry date.
9. For DAW, the prescriber has to write on Rx paper and electronically transmitted Rx must state
another brand of a generically equivalent product identical in dosage may be dispensed.
10. A pharmacist must write GEQ for the drug dispensed on the Rx label if it is not a brand name or
brand is not available and must tell purchaser. If drug product selection takes place, the brand
name or the name of the manufacturer or the supplier shall be noted on Rx label. This rule does
not apply to inpatient medical institution.
11. When a pharmacist receives a prescription for a brand name drug, the pharmacist may or when a
purchaser requests a lower cost GEQ drug, the pharmacist shall dispense a lower cost drug but not
higher cost GEQ drug if available in the pharmacy. Its a federal law.
12. A pharmacist, who substitutes a drug knowing or intending that it will be used, is subject to
licensure discipline including fines, suspension, revocation, probation, restitution and community
services.
13. A pharmacist shall not knowingly dispense a prescription after the death of prescriber or patient.
14. Vouchers intended for filling from the pharmacys stock and starter dose packs from
pharmaceutical companies are legal for community pharmacies to possess for the dispensing of
prescription drugs.

Copy Right protected Page 1

 15. A pharmacist has to dispense new vial or bottle each time on refill despite patients request to
dispense in old one. Both parts (body & closure) must be replaced. If the container is glass then it
can be reused.
16. Prescription drugs package inserts include adverse reactions, contraindication, symptoms &
treatment of overdosing, and date of the most recent revision of the labeling.
17. NDC is a 10 or 11 number system assigned by FDA that aids in identifying a drug product. First five
numbers represent manufacturer, next four drug and last two package size. The NDC may be used
for reimbursement purposes.
18. Essential parts of a prescription are full name of the patient, prescribers printed name and
address, drug name and strength, quantity prescribed, directions for use and number of refills if
any. PRN means a years supply from the date of issuance.
19. Federal Medicare Rx retention period is 10 years. HCFA is responsible for Medicare programs and
Medicare beneficiaries are covered under the Medicare Modernization Act of 2003. Federal
government through the CMC pays a portion roughly 50% of the Medicaid prescription drug charge
back to the states.
20. In order to be reimbursed by Medicare Part D, pharmacy personnel must complete annual training
of minimum of 4 hours for both pharmacist and techs. The records must be kept for 10 years. A
pharmacy must possess NPI if it plans to electronically bill Medicare or Medicaid for prescriptions.
21. When explaining Medicare Plan D program to married couple, the pharmacist should emphasize on
the original deductible, the monthly premium and the donut hole. Major objectives for developing a
formulary are to reduce inventory and allow therapeutic substitution. Sponsor of Plan D programs
must provide a broad choice of formulary drugs for anticonvulsants, antidepressants,
antineoplastics and antipsychotics.
22. Medicare Plan D is voluntary for persons on Medicare and insurance companies may limit
prescription drug quantities to 30 days supply for some drugs.
23. As per law, in retail pharmacies once the legend drugs have been dispensed and have left the
control of pharmacist, they cannot be returned or exchanged for resale. However, if a pharmacist
dispenses wrong medication then it can be exchanged for the correct one and should be kept
separate from stock inventory.
24. Although discourage by FDA, the prescriber can prescribe off label use of drugs and pharmacist
using discretion may dispense. Information about off label use can be found in ASHF.
25. A pharmacist has to counsel with patient under the section of OBRA 1990. Patient can waive. A
pharmacist will offer counseling on new Rx, refill orders and once yearly on maintenance
medications.
26. OBRA 1990 applies to state run Medicaid plans and it imposes a requirement that each state
develop regulations requiring pharmacies that participate in the program to provide DUR and
patient counseling on covered drug. Pharmacist will monitor drugs that are appropriate, medically
necessary, pattern of fraud, abuse, gross overuse, underutilization and appropriate use of generic
products.
27. HIPPA (Health Insurance Portability and Accountability) emphasizes the security, privacy and safety
of health related information. It was issued in 1996. Its a Federal law. HIPPA assures health
insurance portability, reduces health care related frauds and abuse. Parents can pick up Rx record
of children if they are under 18 years.
28. The Prescription Drug Marketing Act (PDMA) prohibits pharmacies from storing, dispensing or
purchasing Rx drug samples and requires state board of pharmacy to license drug wholesalers.
PDMA was enacted to prevent diversion and distribution. Penalties include imprison (incarceration),
criminal prosecution and fines up to $ 250,000.

Copy Right protected Page 2

 29. Once a prescription is dispensed then it remains the property of the dispensing pharmacy and
patients or their designees or agents may have copies of prescription. A prescription shall be
numbered, dated and initialed by the dispensing pharmacist at the time of first filling.
30. The Dingle Bill Act (Rx marketing Act 1987) prohibits the shipping of drugs between two states
without registration (mail order).
31. Kefauver Harris Amendment is known as Drug Efficacy Amendment. This law requires that all
marketed drugs in US have to be safe as well as effective. It was an amendment to FD & C Act
required examination of all Rx medications manufactured between 1938 and 1962.
32. Durham Humphrey Amendment 1951 states that Caution: Federal law prohibits dispensing
without a prescription. This rule does not apply to institutions and CS dispensed in blinded clinical
studies.
33. FDA Modernization Act 1997 replaces Durham Humphrey Amendment and now Rx only is used
on prescription legend drugs. Pharmacists dispense prescription drugs under FD & C Act of 1938.
34. Class I recall is generally issued when drug is believed to cause serious adverse health problems
including death. Patient should also be informed.
35. Class II recall involves when there is a temporary or reversible medical consequence.
36. Class III recall exists when the use of a product is not likely to cause adverse health problems.
37. Phase III is the largest human testing phase in drug development. In this phase, data on safety
and efficacy are gathered through a diverse test population.
38. Phase IV is post marketing surveillance and it involves adverse drug reports and must be reviewed
by manufacturer promptly. The FDA utilizes Phase 4 data to determine whether or not a product
should remain on the market.
39. Ephedrine (all isomers) is included in schedule V. It is excluded from schedule V if it does not alter
or change or cause weight loss. Ephedra is no longer available in dietary supplement.
40. Tamper resistant packaging provides protection against intentional contamination of OTC drugs.
Aerosols, lozenges and OTC products used in hospital and not accessible to the general public are
exempted from this act.
41. For clinical thermometers, a manufacturer shall submit a complete application with requisite fee
and 2 samples that the manufacturer desire to sell in MI. The MI board shall certify thermometer if
it complies with the standard.
42. The documentation required for the automated device is name and address of pharmacy
responsible for operation, manufacturers name and model number, and quality assurance policy
and procedure. Records shall be maintained for 5 years and is subject to review by board. Use of
medical devices such as automated machines and infusion pumps are subject to board approval.
43. The USP recommends that Rx labels used when a medication is dispensed in unit dose from a
hospital or institutional pharmacy bear an expiration date of 25% of the time remaining on the
manufacturers stock bottle or 6 months from the date repackaged, whichever is earlier.
44. Consumer Product Safety Commission is responsible for PPP Act. PPP Act (Poison Prevention
Packing Act) was introduced in 1970. It was to protect children under 5. Following drugs are
exempted from PPP Act: SL/oral NTG, epipen, ISDN tabs (10 mg or less), methylprednisolone,
effervescent tabs of ASA, APAP and potassium chloride, cholestyramine, mebendazole and
pancrelipase tabs. The basic rule is that all Rx must be dispensed with safety caps unless when a
prescriber or patient asks for nonsafety caps. Pharmacist should have signed request on file for
each prescription. When a hospital pharmacy fills a prescription for an inpatient then child resistant
closures are not required.
45. PPI (Patient Package Insert) is required for accutane, estrogens, progesterone, chantix, OCPs,
avandia, NSAIDs, isoprotereonol, IU devices, coumadin, antidepressants and adderall salts. PPI
should be given on new Rx and each time on refill.

Copy Right protected Page 3

 46. The pharmacy department shall be locked when the pharmacist is not in the premises. During the
absence of pharmacist the services of a pharmacist shall be available on an on call basis. A
pharmacist cannot work under the influence of alcohol. Under legislation, intoxication occurs when
the practitioners blood alcohol is more than 0.05 grams/ml of blood which is lower than 0.08 g/ml
needed for operating motor vehicle.
47. The pharmacist who fails to report colleague, could be disciplined by the board of pharmacy. The
ground/sanctions for licensure sanctions are negligence, incompetence, intoxication, substance
abuse, mental incapacity, and conviction of crimes, failure to comply with subpoena, creating false
records, fraud and deceit.
48. There are six attempts on NAPLEX and on MI pharmacy law and after failing all attempts,
pharmacy intern can take board approved course or submit a certificate which is approved by
board.
49. For semi solid compounded Rx, the expiration date is 6 months and for liquid Rx, the expiration
date is 14 days.
50. The board or board inspector can enter any premises or building on reasonable time for inspection
and cannot inspect financial data, sales data, pricing data, personal and research data.
51. Sales/transaction report is not necessary for audit purpose.
52. The FDA makes the determination that drugs are safe and effective for intended purpose when it
approves an NDA for an individual drug. The FDA, state or federal authorities, manufacturer, the
board of pharmacy, and law enforcement agencies can recall any drug from market.
53. DEA, which is part of DOJ (department of justice), decides if a substance will be controlled or not.
54. The proper expiration date used on insulin product is 2 years from the date manufactured.
55. USP requirement for refrigerator is 36 to 46 F or 2 to 8 C and room temperature is 59 to 86 F or 15
to 30 C.
56. The Medwatch program is to report adverse events of approved products of FDA.
57. A pharmacist cannot compound commercially available products or version of FDA approved drugs
or drugs which have been withdrawn from the market because it was unsafe. Under the FDA rules
a pharmacy can advertise to through brochures that pharmacy compounds topical preparations and
sterile parental admixtures. A pharmacy can compound and fill a formula of topical prescription
shared with physician and can compound half pound extra for future refills.
58. Guidelines for determining the expiration date for repacking of a drug product by a pharmacy
include not more than the expiration date on the original package and not more than one year from
the date of packaging.
59. All community pharmacies shall be equipped with alarm and security system to prevent theft and
diversion of drugs.
60. Both the federal and individual state governments have authority to regulate controlled substances.
The Federal Trade Commission (FTC) regulates the advertising of OTC drugs, medical devices and
cosmetics and FDA regulates advertising of legend prescription drugs.
61. Narrow therapeutic index drugs are digoxin, coumadin, phenytoin and theophylline.
62. Orange book (electronic or hard copy) is approved drug products with Therapeutic Equivalence
Evaluations. It uses a two letter (A & B) coding system. The major objective is to compare drug
products that are multisource. The designation A and AB means that products can be substituted or
interchangeable for one another for the same strength and dosage.
63. In USA, a drug patent is 17 years. Waxman Hatch Amendment known as the Drug Price
Competition and Patent Term Restoration Amendment of 1984.
64. According to pharmacies, drug stores and apothecary shops Act of 1927, basically limited the
ownership of community pharmacies to individual pharmacists or to legal entities, such as
partnership or corporation where at least 25% of the ownership was vested in a pharmacist.

Copy Right protected Page 4

 65. In hospitals, prescription/nonprescription and biologics must be bar coded. Manufacturers
expiration date is not required on the label of unit dose packages prepared in hospitals.
66. Labels on cosmetic packages must have ingredients listed in descending order of concentration.
Directions for OTC drugs should be in simple language.
67. Dietary supplements and vitamins are exempted from the FDA regulations concerning expiration
date.
68. Grandfathered drugs are often not listed in the Orange book. These drugs were marketed before
FD & C Act of 1938.
69. Antimicrobial preservatives and coloring agents are required to be included on the labels of
pharmaceuticals products.
70. Laminar Flow Hood certification is done every 6 months.
71. Control substance Act (CSA) places medicinal substances in schedules in descending order based
on their potential for abuse, psychological or physiological dependence and medical use. These
substances are denoted by letter C. A control substance license is waived for the following
employees of drug enforcement administration, US customs, US food and drug administration, a
federal officer and Michigan state officer while engaged in official duties.
72. DEA regulations allow a hospital pharmacy to supply a limited number of doses of controlled
substance drugs to the emergency room if the drugs are stored in a locked cabinet.
73. Federal transfer notice appears on CS II to IV but not on CS V.
74. Drugs in CS III to IV can be refilled if authorized up to 5 times in six months from the date Rx was
issued and CS V can be refilled up to one year from the date of issuance.
75. Schedule I is one which has no accepted medical use in US and has a highest potential for abuse.
Examples of CS I are peyote, heroin, marijuana, mescaline and LSD.
76. CS can be mailed through US postal service, FedEx, and UPS. The USPS still has regulations about
not shipping poisonous and alcoholic beverages but others two not. The inner container must be
marked with patients name and address and name of pharmacy and outer wrapper or container
must be plain with no markings of any kind.
77. Pharmacists are not permitted to manufacture, distribute, prescribe or dispense a CS without
proper authorization, usually in the form of a legal prescription.
78. Medicare, managed by the federal government, is the nation's largest health insurance program.
Medicare provides coverage for around 40 million Americans, or a little more than 10% of the
population of the U.S.
79. While Medicare is administered by the federal government, Medicaid is a joint federal and state
program that helps people with low income and limited resources pay for medical costs. Some
people are referred to as "dual eligible." This means that they are eligible for both Medicaid and
Medicare, and will get government aid for their part of Medicare costs.
80. Medicare provides health insurance coverage for people who are 65 years or older, for some
disabled people under the age of 65 years, and for people of all ages with kidney failure who are
treated with dialysis or with a kidney transplant.
81. Medicare Part A is hospital insurance. It helps pay for hospital visits, care in a skilled nursing
facility, hospice care, and some home health care. Medicare Part A does not have a monthly
premium. Medicare Part A does not cover prescription drugs for outpatients.
82. Medicare Part B is medical insurance. It helps pay for doctors' services, outpatient hospital care,
physical therapy, and home health care. Most people who have Medicare Part B have to pay a
monthly premium. Medicare Part B covers a limited number of prescription drugs for outpatients.
83. Medicare Part A plus Medicare Part B is considered "original Medicare." Patients with original
Medicare will have a "red, white, and blue" insurance card. The card will contain the patient's ID
number (usually their Social Security number with an additional letter). The card also indicates if
the patient is eligible for Part A or Part B, or both.

Copy Right protected Page 5

 84. Some people might get a Medigap policy, or supplemental coverage that helps pay deductibles,
coinsurance, and other costs that are not covered by original Medicare. Medigap policies are offered
by private insurance companies, not by the federal government.
85. Medicare Part D is a prescription drug plan. There are a lot of different choices, since these plans
are administered by private insurance companies and approved by Medicare. Part D coverage is
optional, and can be added on to "original Medicare." Most people who have Medicare Part D plans
will pay a monthly premium. Prescriptions for patients with Part D plans are processed just like
those for any other insurance company (e.g., Express Scripts, WellPoint, etc). Patients will have a
separate insurance card indicating which insurance company you will use to process their Rx.
86. A Medicare Advantage Plan, also called a Medicare Health Plan, is an alternative to original
Medicare (Medicare Part A and Medicare Part B) and possibly Medicare Part D. Medicare Advantage
Plans are run by private companies...like health maintenance organizations (HMOs) or preferred
provider organizations (PPOs)...but approved by Medicare. Medicare Advantage Plans are
sometimes referred to as Part C.
87. Part D prescription drug plans pay for most prescription drugs in the outpatient setting. This
includes biological products; insulin; some vaccines; and medical supplies associated with the
injection of insulin like syringes, needles, alcohol swabs, and gauze. Part D plans are not required
to pay for the following:
Drugs used for weight loss (e.g., orlistat [Xenical], etc) or for anorexia and weight gain (e.g.,
megestrol [Megace], etc);
Drugs used to promote fertility (e.g., clomiphene [Clomid], chorionic gonadotropin [Pregnyl],
etc);
Drugs used for cosmetic purposes or hair growth (e.g., minoxidil [Rogaine], etc);
Drugs used for the symptomatic relief of cough and colds (e.g., benzonatate [Tessalon], etc);
Prescription vitamins and mineral products, except prenatal vitamins and fluoride preparations;
Nonprescription drugs;
Drugs for which the manufacturer seeks to require that associated tests or monitoring services
be purchased exclusively from the manufacturer or its designee as a condition of sale;
Barbiturates (e.g., phenobarbital, etc);
Benzodiazepines (e.g., alprazolam [Xanax], diazepam [Valium], temazepam [Restoril], etc)
88. Part B also pays for durable medical equipment (DME) supply drugs, like nebulized drugs and drugs
for infusion, when they are dispensed from a retail pharmacy for people living at home. You will
need the patient's "red, white, and blue" card to process these prescriptions.
Part B covers supplies for patients with diabetes, including:
blood glucose monitors;
blood glucose test strips;
lancet devices and lancets;
glucose control solutions for checking the accuracy of testing equipment and test strips.
89. Donut hole or coverage gap: After a patient and his or her plan have spent a certain amount of
money (i.e., the patient's yearly deductible plus co-pays plus what the insurance company pays for
prescriptions), the patient must pay out-of-pocket for the cost of all prescription drugs. However,
after a certain amount of money is spent out-of-pocket ($4800 total for 2013, but this changes
from year to year), catastrophic coverage kicks in and starts paying for prescription drugs again.
With catastrophic coverage, the patient will only have to pay a small copay. Some Part D plans pay
a certain amount toward prescription drug costs during the coverage gap. However, these plans
typically cost more than those that don't pay during the coverage gap. When a patient "falls into
the donut hole," reducing prescription drug costs can help make sure that he or she can continue
to get necessary prescription drugs.

Copy Right protected Page 6

 90. Extra Help or low-income subsidy: For certain individuals who meet qualifications based on income,
the government subsidizes the cost of prescription drug plans (i.e., Medicare Part D). Premiums,
deductibles, and co-pays can be either cheaper, or completely paid for by the government subsidy.
Plus, people who get Extra Help won't have a coverage gap.
91. Individuals first become eligible for Medicare in the three months before turning age 65 and
through the three months after turning 65. They can sign up for a Medicare Part D plan during this
six month period. Those who are younger and get Medicare because of a disability can join a Part D
plan during the three months before or the three months after the 25th month of their cash
disability payments.
92. Each year, open enrollment for Part D plans begins on October 15th and ends on December 7th.
This is the period of time where folks can change plans, or enroll if they had not enrolled before.
(People who do not enroll during the three months before and three months after they turn 65 are
likely to end up paying more if they enroll later). Changes made during open enrollment take effect
on January 1st of the following year.
93. Audit: An audit refers to a formal review of compliance with a particular set of internal (e.g.,
policies and procedures) or external (e.g., laws and regulations) standards used as base measures.
94. Centers for Medicare and Medicaid Services (CMS): An agency within the Department of Health and
Human Services (HHS) that is responsible for the federal Medicare and Medicaid programs.
95. Downstream Entity: Any party that enters into a written arrangement below the level of
arrangements between first-tier entities and a plan sponsor. This continues down to the level of the
provider of health or administrative services. Consider a PBM contracting with pharmacies.
Examples: pharmacies, marketing firms, claims processors, billing agencies.
96. Edit: Logic within a plan sponsor's claims processing system that selects certain claims, evaluates
or compares information on the selected claims or other accessible source, and depending on the
evaluation, takes action on the claims, such as pay in full, pay in part, or suspend for manual
review.
97. First-tier Entity: Any party that enters into a written arrangement to provide administrative
services or health care services for a Medicare-eligible individual. Examples: pharmacy benefit
manager (PBM), contracted hospitals and clinics.
98. Low Income Subsidy: A program to provide low-income Medicare beneficiaries with extra
assistance with premiums and cost sharing under Medicare Part D. Low-income subsidy applicants
who are not deemed eligible for the subsidy will have to meet an income and asset test, and
eligibility will be determined by either the state Medicaid agency or the Social Security
Administration. Beneficiaries may fall into two groups: those who qualify for full subsidy with no
coverage gap and nominal cost sharing, and those beneficiaries who qualify for other low-income
benefits with reduced deductibles and coinsurance sliding-scale premium subsidies.
99. Medicare Part D Plan: A prescription drug plan (PDP), a Medicare Advantage prescription
drug (MA-PD) plan, or a Program of All-inclusive Care for the Elderly (PACE) plan offering
qualified prescription drug coverage, or a cost plan offering qualified prescription drug
coverage. This includes employer- and union-sponsored plans.
100. Medicare Part D Plan Sponsor: Refers to a prescription drug plan (PDP) sponsor,
Medicare Advantage (MA) organization offering a Medicare Advantage prescription drug
(MA-PD) plan, a Program of All-inclusive Care for the Elderly (PACE) organization offering
a PACE plan including qualified prescription drug coverage, and a cost plan offering
qualified prescription drug coverage. This includes employer- and union-sponsored plans.
101. Pharmacy Benefit Manager (PBM): An entity that provides pharmacy benefit management
services, including contracting with a network of pharmacists; establishing payment levels for
network pharmacists; negotiating rebate arrangements; developing and managing formularies,

Copy Right protected Page 7

 preferred drug lists, and prior authorization programs; maintaining patient compliance programs;
performing drug utilization review; and operating disease management programs. Many PBMs also
operate mail order pharmacies or have arrangements to include prescription availability through
mail order pharmacies.
102. Pharmacy & Therapeutics (P&T) Committee: A committee, the majority of whose members
shall consist of individuals who are practicing physicians or practicing pharmacists, that is charged
with developing and reviewing a formulary. A P&T committee shall include at least one practicing
physician and at least one practicing pharmacist, each of whom is independent and free of conflict
with respect to the plan sponsor, and at least one practicing physician and at least one practicing
pharmacist who have expertise in the care of elderly or disabled persons.
103. Provider: Any Medicare provider or supplier. For example, hospitals, skilled nursing facilities,
home health agencies, outpatient physical therapy, comprehensive outpatient rehabilitation
facilities, renal dialysis facilities, hospice, physicians, non-physician practitioners, laboratories,
suppliers, pharmacies, or pharmacists.
104. Related Entity: Is an entity related to a plan sponsor by common ownership which performs
some management functions under contract, or furnishes services to Medicare enrollees, or leases
real property or sells materials to the plan sponsor. An example is where a plan sponsor is the
parent company of its own in-house PBM.
105. State Pharmaceutical Assistance Program (SPAP): SPAP are state-run programs that provide
financial assistance for the purchase or provision of supplemental prescription drug coverage or
benefits on behalf of Medicare Part D eligible individuals.
106. TrOOP (True Out Of Pocket Costs): The out-of-pocket amount a beneficiary must spend on
Medicare Part D covered drugs to reach catastrophic coverage. For example, the original standard
benefit design was $250 deductible + $500 beneficiary coinsurance during initial coverage + $2850
coverage gap = $3600. Of course, these amounts may increase each year. Payments counting
toward TrOOP include payments by beneficiary, family member or friend, SPAP, a charity, or a
personal health savings vehicle (flexible spending account, health savings account, medical savings
account). Payments that do NOT count toward TrOOP include Medicare Part D premiums and
coverage by other insurance plans, group health plans, government programs (non-SPAP),
workers' compensation, Medicare Part D plans' supplemental or enhanced benefits, or other third
parties.

Copy Right protected Page 8