Department of Health and Human Services

OFFICE OF 

INSPECTOR GENERAL 

T M -

EMPORARY  EDICARE
A D D
PPROVED  RUG  ISCOUNT 

C :  A D
ARD NALYSIS OF  RUG 

P
RICES

Daniel R. Levinson

Inspector General 

October 2005

OEI-05-05-00020
 Office of Inspector General 
http://oig.hhs.gov 
The mission of the Office of Inspector General (OIG), as mandated by Public Law 95-452, as 
amended, is to protect the integrity of the Department of Health and Human Services (HHS) 
programs, as well as the health and welfare of beneficiaries served by those programs. This 
statutory mission is carried out through a nationwide network of audits, investigations, and 
inspections conducted by the following operating components: 
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Office of Evaluation and Inspections 
The Office of Evaluation and Inspections (OEI) conducts management and program evaluations 
(called inspections) that focus on issues of concern to HHS, Congress, and the public.  The 
findings and recommendations contained in the inspections generate rapid, accurate, and up-to-
date information on the efficiency, vulnerability, and effectiveness of departmental programs.  
OEI also oversees State Medicaid Fraud Control Units which investigate and prosecute fraud and 
patient abuse in the Medicaid program. 
Office of Investigations 
The Office of Investigations (OI) conducts criminal, civil, and administrative investigations of 
allegations of wrongdoing in HHS programs or to HHS beneficiaries and of unjust enrichment 
by providers.  The investigative efforts of OI lead to criminal convictions, administrative 
sanctions, or civil monetary penalties.  
Office of Counsel to the Inspector General 
The Office of Counsel to the Inspector General (OCIG) provides general legal services to OIG, 
rendering advice and opinions on HHS programs and operations and providing all legal support 
in OIGs internal operations.  OCIG imposes program exclusions and civil monetary penalties on 
health care providers and litigates those actions within HHS.  OCIG also represents OIG in the 
global settlement of cases arising under the Civil False Claims Act, develops and monitors 
corporate integrity agreements, develops compliance program guidances, renders advisory 
opinions on OIG sanctions to the health care community, and issues fraud alerts and other 
industry guidance.    E X E C U T I V E   S U M M A R Y  

OBJECTIVE 
To determine the extent to which prices offered by Medicare general 
drug card sponsors fluctuated between June and December 2004. 
BACKGROUND 
The Medicare Prescription Drug, Improvement, and Modernization Act 
of 2003 (MMA), Public Law 108-173, added an outpatient prescription 
drug benefit to Medicare under Part D.  As part of the MMA, Congress 
also enacted the temporary Medicare Prescription Drug Discount Card 
and Transitional Assistance Program.  This voluntary program 
attempts to reduce prescription drug costs for seniors before the Centers 
for Medicare & Medicaid Services (CMS) implements the Medicare drug 
benefit in January 2006. 
CMS administers this voluntary program through approved drug card 
sponsors.  Sponsors are private companies, including health insurance 
companies, chain pharmacies, and managed care firms. 
To enable Medicare beneficiaries to select a drug discount card, drug 
card sponsors provide pricing and pharmacy data to a CMS contractor 
for display on CMSs Medicare Web site 
(www.medicare.gov/AssistancePrograms).  CMS contracted with a 
program safeguard contractor to monitor drug card sponsors pricing 
information to identify bait and switch activities.  In addition, the 
Office of Inspector General assured CMS that it would monitor prices. 
We reviewed weekly drug card pricing files submitted by general drug 
card sponsors for the period June 21 through December 27, 2004.  Our 
final analysis included approximately six million observations.  
FINDINGS 
Two-thirds of drug prices did not fluctuate between June and 
December 2004. Two-thirds of the six million drug prices submitted by 
drug card sponsors did not change between June 21 and      
December 27, 2004. 
  OEI-05-05-00020  TEMPORARY MEDICARE-APPROVED DRUG DISCOUNT CARD:  ANALYSIS OF DRUG PRICES  i  E X E C U T I V E   S U M M A R Y  
Among the one-third of drug prices that did fluctuate, changes were 
infrequent and included both increases and decreases. Of the drug 
prices that did fluctuate, only about 1 percent of the prices changed in 
most weeks.  Seventy-three percent of the prices changed two times or 
less between June and December 2004. 
Of the prices that changed, the average median increase in price was 
approximately 7 percent in any given week.  The median price decrease 
had more variation. In 10 of the 27 periods examined, the median 
decrease in prices exceeded 15 percent.   
Most drug card sponsors exhibited similar patterns of minimal 
fluctuation in prices. 
SUMMARY 
Based on these findings, we do not recommend that CMS take any 
action at this time.  
  OEI-05-05-00020  TEMPORARY MEDICARE-APPROVED DRUG DISCOUNT CARD:  ANALYSIS OF DRUG PRICES  ii    T A B L E   O F   C O N T E N T S  

EXECUTIVE SUMMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
 i 
I N T RO DUC T IO N  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  1

F I N D IN G S  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  6

Two-thirdsof prices did notchange. . . . . . . . . . . . . . . . . . . . . . . . .  6

Increases and decreaseswere infrequent. . . . . . . . . . . . . . . . . . . . .  6

SUMMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  11

E N D NO T ES  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  12

A C K NO WL E D G M E N T S  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  13
   I N T R O D U C T  I O N  

OBJECTIVE 
To determine the extent to which prices offered by Medicare general 
drug card sponsors fluctuated between June and December 2004. 
BACKGROUND 
Medicare Prescription Drug Discount Card and Transitional Assistance 
Program 
The Medicare Prescription Drug, Improvement, and Modernization Act 
of 2003 (MMA), Public Law 108-173, added an outpatient prescription 
drug benefit to Medicare under Part D.  Effective January 2006, all 
Medicare beneficiaries will be able to enroll in private plans that will 
cover a percentage of their drug costs.  Medicare will provide assistance 
with premiums and cost sharing to an estimated 11 million low-income 
beneficiaries.1  Estimates of the Part D drug benefit cost range from 
$47 billion to $58.9 billion for fiscal year 2006.2 
As part of the MMA, Congress also enacted the temporary Medicare 
Prescription Drug Discount Card (drug card program).  This voluntary 
program attempts to reduce prescription drug costs for seniors before 
the Centers for Medicare & Medicaid Services (CMS) implements the 
Medicare drug benefit in January 2006.  CMS reported in December 
2004 that nearly six million beneficiaries had enrolled in the drug card 
program.3 
CMS administers this voluntary program through approved drug card 
sponsors.  Sponsors are private companies, including health insurance 
companies, chain pharmacies, and managed care firms.  To be approved 
as a drug card sponsor, these companies must meet certain 
requirements, including:  
 	 Organizational experience, including processing pharmacy 
claims at the point of sale; 
 	 Ability to provide negotiated prices; 
 	 Capacity to manage the eligibility and enrollment process; and 
 	 Agreement to provide drug-pricing data to CMS. 
There are two classes of drug card sponsors.  General card sponsors 
offer plans to all eligible Medicare beneficiaries, while exclusive card 
sponsors administer drug cards for those Medicare beneficiaries 
enrolled in managed care health plans.  
  OEI-05-05-00020  TEMPORARY MEDICARE-APPROVED DRUG DISCOUNT CARD:  ANALYSIS OF DRUG PRICES  1  I N T R O D U C T I O N  
Drug card sponsors determine the discounts and other features of the 
cards they offer to beneficiaries. Drug card discounts vary among cards 
and may vary within a card program.  Drug card sponsors can offer 
discounts on all drugs allowed by CMS or may cover only a select list of 
drugs (i.e., a formulary).  This formulary may vary throughout the life of 
the program, as can the discounted prices for drugs.   
In addition, drug card sponsors may charge an annual enrollment fee of 
up to $30 or may offer a card without an enrollment fee. Beneficiaries 
may enroll in only one Medicare-approved card at a time. 
Drug Discount Card Pricing Data 
To enable Medicare beneficiaries to select a drug discount card, 
sponsors provide pricing and pharmacy data to Destination Rx, a CMS 
contractor, for display on CMSs Medicare Web site 
(www.medicare.gov/AssistancePrograms).  Sponsors submit weekly 
pricing files to Destination Rx, which uses these data to display 
information about prescription drug pricing at the pharmacy level by 
approved drug card sponsors. 
For each drug discount card, a sponsor can submit multiple pricing files.  
These pricing files allow for variation within drug discount card 
programs that can account for differences in pricing based on income 
levels, geography, or networks of pharmacies.  For example, a drug card 
sponsor can submit one pricing file for very low-income beneficiaries 
and another for all other beneficiaries.  A drug discount card sponsor 
can also submit a pricing file that is specific to a network of pharmacies. 
Drug card sponsors can change their prices at any point during the 
program.  However, if any of the changes are increases that exceed a 
certain threshold, sponsors must explain these increases to CMS.    
Sponsors report pricing data using the Food and Drug Administrations 
National Drug Code (NDC).  The NDC is a unique identifier that 
contains information about the manufacturer, the product strength and 
dosage, and the package size of each drug product.  
Oversight 
On August 27, 2004, CMS announced a contract with Integriguard, a 
Program Safeguard Contractor (PSC), to monitor activities associated 
with the drug cards.  According to CMS, a critical task of this PSC is a 
weekly assessment of the sponsors drug pricing information to identify 
bait and switch activities.4  In addition, the Office of Inspector General 
(OIG) assured CMS that it would monitor drug prices. 
  OEI-05-05-00020  TEMPORARY MEDICARE-APPROVED DRUG DISCOUNT CARD:  ANALYSIS OF DRUG PRICES  2  I N T R O D U C T I O N  
Concurrent OIG Inspections  
OIG has conducted two additional studies related to the drug card 
program. One study, Assessment of Sponsors Materials Under the 
Medicare-Approved Drug Discount Card Program (OEI-05-04-00190), 
assessed the extent to which drug card sponsors materials promote 
informed choice for beneficiaries. The other study, Medicare-Approved 
Drug Discount Card: Beneficiaries Awareness and Use of Information 
Resources (OEI-05-04-00200), assessed the extent of beneficiaries 
awareness and use of information resources to decide whether to enroll 
in the drug card program and navigate the enrollment process.   
METHODOLOGY 
Data Collection 
We obtained from CMS weekly drug card pricing files submitted by 67 
general drug card sponsors for the period June 21 through 
December 27, 2004. While the drug card program began in May 2004, 
we chose June 21, 2004, as the beginning of our review period due to 
initial problems with the pricing data identified by CMS during early 
implementation.  These pricing files contain the raw data for CMSs 
price comparison Web site, which is designed to provide beneficiaries 
with information they need to compare drug prices among drug card 
sponsors. 
We created a data file containing all weekly prices for every pricing file 
submitted by general drug card sponsors.  This file contains 
approximately 10 million unique combinations of drug card sponsors, 
pricing files, and NDCs.  See Table 1 for additional information 
regarding the weekly drug card pricing files. 
TABLE 1: Drug Card Pricing Files for Review Period 
Number of 
Sponsors  Number of Pricing Files  Number of Different Prices 
67  775  9,970,123 
Range per sponsor:  2 to 30  Range per pricing file:  970 to 87,518 
Mean per sponsor:  12  Mean per pricing file:  12,865 
  OEI-05-05-00020  TEMPORARY MEDICARE-APPROVED DRUG DISCOUNT CARD:  ANALYSIS OF DRUG PRICES  3  I N T R O D U C T I O N  
We excluded from the initial data several types of information that were 
not appropriate for our review.  We removed certain classes of drugs 
from our data file, such as fertility drugs and drugs used for cosmetic 
purposes, which are excluded from the drug card program by statute.5 
Drug card discounts for these drugs are not available to beneficiaries. 
We also eliminated pricing files specific to long-term care pharmacies, 
Indian Tribe and Tribal Organizations and Urban Indian Organizations 
pharmacies, and pharmacies serving territories because these 
pharmacies serve unique populations.6  In addition, we dropped one 
drug card sponsor after we determined that it was not enrolling 
beneficiaries. This drug card sponsor submitted pricing information for 
only the first 2 weeks of our review. 
We further narrowed our review to include only drugs that were 
purchased by beneficiaries during the review period.  Out of the 
universe of approximately 69,000 NDCs, we included data for only the 
22,036 unique NDCs for which drug card sponsors reported prescription 
sales to enrolled beneficiaries between June and November 2004. 
Finally, we eliminated records that did not have enough data for 
analysis. We included only those unique combinations of drug card 
sponsor, pricing file, and NDC for which 2 weeks or more of price data 
were available for analysis.  This reduced our final analysis file of drug 
card sponsors, pricing files, and NDCs to approximately six million. See 
Table 2 for more information regarding the pricing files used in our 
analysis. 
TABLE 2: Drug Card Pricing Files Reviewed:  After Exclusions of 
Drugs, Pricing Files, and Sponsor 
Number of 
Sponsors  Number of Pricing Files  Number of Different Prices 
65  742  5,999,314 
Range per sponsor:  2 to 30  Range per pricing file:  27 to 15,340 
Mean per sponsor:  11  Mean per pricing file:  8,085 
We determined that the pricing information reported by drug card 
sponsors was sufficiently reliable to achieve the objective of this report. 
To assess the reliability of the data, we confirmed that they included the 
  OEI-05-05-00020  TEMPORARY MEDICARE-APPROVED DRUG DISCOUNT CARD:  ANALYSIS OF DRUG PRICES  4  I N T R O D U C T I O N  
elements needed to perform our analysis, used pricing files upon which 
CMS and its contractor performed quality checks prior to posting them 
on the Medicare Web site, and worked with CMS staff to identify any 
data problems. 
Analysis 
We used several methods to examine prices submitted by drug card 
sponsors during the 28 weeks reviewed.  We identified the proportion of 
all drug card prices with no change at all during the review period.  We 
calculated the percentage of prices that changed in each week and the 
percentage of these changes that were increases or decreases.  In 
addition, we examined the data by drug card sponsor to ascertain 
whether specific sponsors were responsible for certain price changes.  
We also calculated a Stochastic Oscillator for the last reported price for 
each combination of drug card sponsor, pricing file, and NDC. A 
Stochastic Oscillator shows the location of the last reported price 
relative to the high/low range over the 28 weeks reviewed. A Stochastic 
Oscillator of 100 means that the last reported price is at its highest level 
while a Stochastic Oscillator of 0 means that the last reported price is at 
its lowest level.  A score between 0 and 100 means that the last reported 
price is between the lowest and highest price. 
Calculations are based on the total available data, excluding missing 
prices.  While the final data set contains approximately six million 
observations, the exact number of sponsors, pricing files, and NDCs 
with reported information might vary from week to week. 
We refer to comparisons between weeks as periods.  While there are   
28 weeks of data in the review period, there are only 27 periods. 
Scope 
It is important to note that this inspection only examines drug card 
sponsors self-reported data as received by CMS staff through CMSs 
contractor.  We did not attempt to determine whether beneficiaries were 
able to receive the prices posted on the Web site by the drug card 
sponsors at their local pharmacies. In addition, we do not generalize 
our results to all prices over the duration of the drug card program. 
This inspection was conducted in accordance with the Quality 
Standards for Inspections issued by the Presidents Council on 
Integrity and Efficiency. 
  OEI-05-05-00020  TEMPORARY MEDICARE-APPROVED DRUG DISCOUNT CARD:  ANALYSIS OF DRUG PRICES  5    F I N D I N G S

Two-thirds of drug prices did not fluctuate  Two-thirds of drug prices submitted 
between June and December 2004  by drug card sponsors did not 
change at all between June 21 and 
December 27, 2004. Of the six million prices submitted by drug card 
sponsors, approximately four million did not change over the 28-week 
period. See Chart 1 for an overall analysis of price change. 
CHART 1 
Percentage of 
prices that 
changed, 
 JuneDecember 
2004  Price Change 
33% 
No Change 
67% 
Source:  OIG analysis of JuneDecember 2004 Medicare drug card sponsors pricing files, 2005 
Among the one-third of drug prices that did  Of the prices that fluctuated, only 
a small percentage changed in 
fluctuate, changes were infrequent and included 
any given week 
both increases and decreases 
Except during two periods, 
drug card sponsors submitted changes for about 1 percent of all prices. 
For the two periods that are exceptions, drug card sponsors submitted a 
larger percentage of price changes compared to the other 25 periods.  
See Chart 2 for analysis of price changes by period. 
  OEI-05-05-00020  TEMPORARY MEDICARE-APPROVED DRUG DISCOUNT CARD:  ANALYSIS OF DRUG PRICES  6  F I N D I N G S  
CHART 2 
Weekly pricing files:  Percentage of drug price 
changes by period 
25 % 
20 % 
e  15 % 
g
a
t
n
e
c
r
e
P 10 % 
5% 
0% 
Period 1P eriod 2P eriod 3P eriod 4Period 5P eriod 6P eriod 7P eriod 8Period P9e riod 1P0e riod 1P1e riod 1P2e riod 1P3e riod 1P4e riod 1P5e riod 1P6e riod 1P7e riod 1P8e riod 1P9e riod 2P0e riod 2P1e riod 2P2e riod 2P3e riod 2P4e riod 2P5e riod 2P6e riod 27 
Period 
Source: OIG analysis of JuneDecember 2004 Medicare drug card sponsors pricing files, 2005 
More prices changed during period 3 (between weeks 3 and 4) than during any 
other period. Drug card sponsors submitted a larger percentage of 
increases and decreases between weeks 3 and 4 (July 5 and 
July 12, 2004) than between any of the other weeks.  Overall, drug card 
sponsors increased about 11 percent of all prices between these 2 weeks 
and decreased about 12 percent of all prices.   
Analyzing by sponsor, we found that of the 60 sponsors with prices 
posted on the price comparison Web site during weeks 3 and 4, 
18 sponsors were responsible for 95 percent of all the price changes. 
Each of these 18 sponsors increased between 14 and 22 percent of their 
prices, while the remaining 42 sponsors increased between 0 and     
3 percent of their prices.  For the price decreases, these same 
  OEI-05-05-00020  TEMPORARY MEDICARE-APPROVED DRUG DISCOUNT CARD:  ANALYSIS OF DRUG PRICES  7  F I N D I N G
 S  
18 sponsors decreased between 17 and 56 percent of their prices, while 
37 out of the 42 sponsors decreased less than 1 percent of their prices.  
These large price fluctuations only occurred once throughout the study 
period: during period 3, which was relatively early in the program. It is 
possible that some of the large fluctuations are due to changes in prices 
negotiated by pharmacy benefit mangers.  For example, of the 18 drug 
card sponsors responsible for 95 percent of the price changes, 16 share 
the same pharmacy benefit manager.  
About 4 percent of the prices changed during period 16.  Two drug card 
sponsors were responsible for 62 percent of all the prices that changed 
between weeks 16 and 17, October 4 and October 11, 2004.  These two 
drug card sponsors submitted multiple pricing files for low-income and 
all other beneficiaries, with up to seven specific pricing files for 
pharmacy chain contracts.  The changes predominantly appear in two 
pricing files that are related to specific pharmacy chain contracts and do 
not occur across all price files submitted by these two sponsors.  
Of the prices that fluctuated, most changed only a few times 
Of the approximately two million prices that drug card sponsors 
submitted that changed, 53 percent had only one change between June 
and December 2004.  Another 20 percent of prices had two changes 
during this 28-week period.  Only 147 prices out of 2 million had 10 or 
more changes detected between June and December 2004.  Over the 
28 weeks, some prices increased compared to the previous week and 
then decreased in the following week. 
Of the prices that fluctuated, some increased, while at the same time 
others decreased 
Among prices that changed, the increase in price ranged from 4 to  
21 percent with an average median increase of 7 percent in any given 
period.  In 17 out of 27 periods examined, the median reported increase 
in prices was approximately 7 percent or less.  In only two periods were 
the median reported increases greater than 10 percent. 
The median price decreases were more varied.  In 10 of the 27 periods 
examined, the median decrease in prices exceeded 15 percent.  In 5 of 
the 27 periods, the median decrease in prices was less than 5 percent. 
See Chart 3 for the median percentage price increases and decreases 
between June and December 2004. 
  OEI-05-05-00020  TEMPORARY MEDICARE-APPROVED DRUG DISCOUNT CARD:  ANALYSIS OF DRUG PRICES  8  F I N D I N G S  
CHART 3 
Analysis of weekly price changes: Median 
percentage of increases and decreases by 
period 
30 
25 
e
g 20 
n
a
h
C
Me d i an 
e 
g 15  I nc reas e 
a
nt Me d i an 
e De c reas e 
c
er 10 
P
5 
0 
PeriodP e1riodP e2riodP e3riodP e4riodP e5riodP e6riodP e7riodP e8rioPde ri9odP e1ri0odP e1ri1odP e1ri2odP e1ri3odP e1ri4odP e1ri5odP e1ri6odP e1ri7odP e1ri8odP e1ri9odP e2ri0odP e2ri1odP e2ri2odP e2ri3odP e2ri4odP e2ri5odP e2ri6od 27 
Period 
Source: OIG analysis of JuneDecember 2004 Medicare drug card sponsors pricing files, 2005 
While 67 percent of the prices remained the same throughout the 28 
weeks we reviewed, 20 percent of the last reported prices were at their 
highest reported price. Eleven percent were at their lowest reported 
price.  The remaining 1 percent were between the highest and lowest 
price reported between June and December 2004.* 
* Numbers do not add up to 100 percent due to rounding. 
  OEI-05-05-00020  TEMPORARY MEDICARE-APPROVED DRUG DISCOUNT CARD:  ANALYSIS OF DRUG PRICES  9  F I N D I N G S  
Most drug card sponsors exhibit similar patterns of minimal fluctuation in 
prices 
Forty-four of the sixty-five drug card sponsors submitted price changes 
both increases and decreasesfor 2 percent or less of all their prices. 
Reported prices changed by drug card sponsors ranged from a low of  
0.5 percent of their prices to a high of 6 percent.  At the high end of the 
range, two drug card sponsors increased or decreased about 6 percent of 
their prices within the entire review period of June 21 and 
December 27, 2004. 
Many of the drug card sponsors that exhibited similar patterns of 
changes in prices were affiliated with the same pharmacy benefit 
managers. For example, 16 different drug card sponsors affiliated with 
the same pharmacy benefit manager each changed 2.2 percent of their 
prices.  It is possible that these changes may be due to changes in the 
pharmacy benefit managers negotiated price rather than changes made 
by individual drug card sponsors.   
  OEI-05-05-00020  TEMPORARY MEDICARE-APPROVED DRUG DISCOUNT CARD:  ANALYSIS OF DRUG PRICES  10    S U M M A R Y  

The objective of this inspection was to determine the extent to which 
prices offered by Medicare drug card sponsors fluctuated between 
June and December 2004. We found that two-thirds of the six million 
prices submitted by drug card sponsors did not change at all during the 
study period.  Among the one-third of prices that did change, only about 
1 percent changed in most weeks. Further, most drug card sponsors 
exhibited similar patterns of minimal fluctuation in prices. Based on 
these findings, we do not recommend that CMS take any action at this 
time. 
  OEI-05-05-00020  TEMPORARY MEDICARE-APPROVED DRUG DISCOUNT CARD:  ANALYSIS OF DRUG PRICES  11    E N D N O T E S  

1	 Centers for Medicare & Medicaid Services, Medicare Fact Sheet:  Final 
Rules Implementing the New Medicare Law:  A New Prescription Drug 
Benefit for All Medicare Beneficiaries, Improvements to Medicare 
Health Plans and Establishing Options for Retirees, January 21, 2005, 
p. 3. 
2	 Congressional Budget Office, The Budget and Economic Outlook: 
Fiscal Years 2006 to 2015, January 2005, p. 55.  Also, Centers for 
Medicare & Medicaid Services, Releasing the HHS Proposed Budget 
for FY 2006, February 7, 2005. 
3	 Centers for Medicare & Medicaid Services, Fact Sheet:  Medicare 
Modernization Benefits in the First Year, December 8, 2004.   
4  Centers for Medicare & Medicaid Services Press Release, CMS 
Strengthens Efforts to Reduce Fraud and Abuse in Medicare and 
Medicaid, August 27, 2004. 
5  MMA, Title I Sec. 101, Subpart 5, Sec. 1860D-41 (a)(2) references 
exclusions at Title I, Sec. 101, Subpart1, Section 1860D-2 (e) (2), which 
references exclusions in the Social Security Act, Title XIX, Sec. 
1927(d)(2) except (E) and 1927(d)(3). 
6  Centers for Medicare & Medicaid Services Web site, Overview of 
Medicare Prescription Drug Discount Card and Transitional Assistance 
Program, http://www.cms.hhs.gov/discountdrugs/overview.asp, accessed 
September 16, 2004. 
  OEI-05-05-00020  TEMPORARY MEDICARE-APPROVED DRUG DISCOUNT CARD:  ANALYSIS OF DRUG PRICES  12    A C K N O W L E D G M E N T S  

This report was prepared under the direction of William C. Moran, 
Regional Inspector General for Evaluation and Inspections in the 
Chicago regional office, and Ann Maxwell, Assistant Regional Inspector 
General. Other principal Office of Evaluation and Inspections staff who 
contributed include: 
Thomas Komaniecki, Project Leader 
Laura Torres, Program Analyst 
Linda Boone Abbott, Program Specialist 
Tricia Davis, Director, Medicare and Medicaid Branch 
Technical Assistance  
Barbara Tedesco, Mathematical Statistician 
Scott Horning, Program Analyst 
  OEI-05-05-00020  TEMPORARY MEDICARE-APPROVED DRUG DISCOUNT CARD:  ANALYSIS OF DRUG PRICES  13