Department of Health and Human Services


OFFICE OF 

INSPECTOR GENERAL 

TEMPORARY MEDICAREAPPROVED DRUG DISCOUNT 


CARD: ANALYSIS OF DRUG 


PRICES


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: 

Office of Audit Services 

The Office of Audit Services (OAS) provides all auditing services for HHS, either by conducting 

audits with its own audit resources or by overseeing audit work done by others. Audits examine 

the performance of HHS programs and/or its grantees and contractors in carrying out their 

respective responsibilities and are intended to provide independent assessments of HHS programs 

and operations in order to reduce waste, abuse, and mismanagement and to promote economy 

and efficiency throughout HHS. 

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-todate 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 OIG’s 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. 
Δ EXECUTIVE SUMMAR 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 CMS’s 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. 

 OE I-05-05-00 020 T E M P O R A RY MEDI C ARE - AP P R O VED DR U G DISC O U N T CA R D : ANALY S I S O F DRUG P R I CES i 
EXE CUTIVE S U MMAR 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. 

 OE I-05-05-00 020 T E M P O R A RY MEDI C ARE - AP P R O VED DR U G DISC O U N T CA R D : ANALY S I S O F DRUG P R I CES ii 
i 

Δ T ABLE OF CONTENTS 

EXECUTIVE SUMMARY ....................................

INTR O D U C T I ON ........................................... 1

FINDI NGS ................................................. 6

Two-thirds of prices did not change ......................... 6

Increases and decreases were infrequent..................... 6

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

ENDN OTE S ............................................... 12

ACKN O W LEDGMENTS .................................... 13
Δ INTRODU C TION 

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. 

 OE I-05-05-00 020 T E M P O R A RY MEDI C ARE - AP P R O VED DR U G DISC O U N T CA R D : ANALY S I S O F DRUG P R I CES 1 
INTROD UCT ION 

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 CMS’s 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 Administration’s 

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 sponsor’s 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. 

 OE I-05-05-00 020 T E M P O R A RY MEDI C ARE - AP P R O VED DR U G DISC O U N T CA R D : ANALY S I S O F DRUG P R I CES 2 
INTROD UCT ION 

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 CMS’s 

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 

Range per sponsor: 2 to 30 

Mean per sponsor: 12 

9,970,123 

Range per pricing file: 970 to 87,518 

Mean per pricing file: 12,865 

 OE I-05-05-00 020 T E M P O R A RY MEDI C ARE - AP P R O VED DR U G DISC O U N T CA R D : ANALY S I S O F DRUG P R I CES 3 
INTROD UCT ION 

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 

Range per sponsor: 2 to 30 

Mean per sponsor: 11 

5,999,314 

Range per pricing file: 27 to 15,340 

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 

 OE I-05-05-00 020 T E M P O R A RY MEDI C ARE - AP P R O VED DR U G DISC O U N T CA R D : ANALY S I S O F DRUG P R I CES 4 
INTROD UCT ION 

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 CMS’s 

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 President’s Council on 

Integrity and Efficiency. 

 OE I-05-05-00 020 T E M P O R A RY MEDI C ARE - AP P R O VED DR U G DISC O U N T CA R D : ANALY S I S O F DRUG P R I CES 5 
Δ FINDINGS

Two-thirds of drug prices submitted 

by drug card sponsors did not 

Two-thirds of drug prices did not fluctuate 

between June and December 2004 

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, 

 June–December 

2004 Price Change 

33% 

No Change 

67% 

Source: OIG analysis of June–December 2004 Medicare drug card sponsors’ pricing files, 2005 

Among the one-third of drug prices that did 

fluctuate, changes were infrequent and included 

both increases and decreases 

Of the prices that fluctuated, only 

a small percentage changed in 

any given week 

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. 

 OE I-05-05-00 020 T E M P O R A RY MEDI C ARE - AP P R O VED DR U G DISC O U N T CA R D : ANALY S I S O F DRUG P R I CES 6 
F I NDING S 

CHART 2 

Weekly pricing files: Percentage of drug price 

changes by period 

0% 

5% 

10 % 

15 % 

20 % 

25 % 

Period 1 Period 2 Period 3 

Period 4

Period 5 Period 6 

Period 7 

Period 8

Period 9 

Period 10 Period 11 Period 12 

Period 13 Period 14 Period 15 Period 16 Period 17 Period 18 Period 19 Period 20 Period 21 Period 22 Period 23 

Period 24 Period 25 Period 26 Period 27 

Period 

Percentage 

Source: OIG analysis of June–December 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 

 OE I-05-05-00 020 T E M P O R A RY MEDI C ARE - AP P R O VED DR U G DISC O U N T CA R D : ANALY S I S O F DRUG P R I CES 7 
F I NDING 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. 

 OE I-05-05-00 020 T E M P O R A RY MEDI C ARE - AP P R O VED DR U G DISC O U N T CA R D : ANALY S I S O F DRUG P R I CES 8 
F I NDING S 

CHART 3 

Analysis of weekly price changes: Median 

percentage of increases and decreases by 

period 

0 

5 

10 

15 

20 

25 

30 

Period 1Period 2Period 3Period 4Period 5Period 6Period 7Period 8Period 9

Period 10Period 11Period 12Period 13Period 14Period 15Period 16Period 17Period 18Period 19Period 20Period 21Period 22Period 23Period 24Period 25Period 26Period 27 

Period 

Percentage Change

M e di an 

I n crea se 

M e di an 

D e crea se 

Source: OIG analysis of June–December 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. 

 OE I-05-05-00 020 T E M P O R A RY MEDI C ARE - AP P R O VED DR U G DISC O U N T CA R D : ANALY S I S O F DRUG P R I CES 9 
F I NDING 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 decreases—for 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 manager’s negotiated price rather than changes made 

by individual drug card sponsors. 

 OE I-05-05-00 020 T E M P O R A RY MEDI C ARE - AP P R O VED DR U G DISC O U N T CA R D : ANALY S I S O F DRUG P R I CES 10 
Δ SUMMAR 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. 

 OE I-05-05-00 020 T E M P O R A RY MEDI C ARE - AP P R O VED DR U G DISC O U N T CA R D : ANALY S I S O F DRUG P R I CES 11 
Δ ENDNOTE 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. 

 OE I-05-05-00 020 T E M P O R A RY MEDI C ARE - AP P R O VED DR U G DISC O U N T CA R D : ANALY S I S O F DRUG P R I CES 12 
Δ ACKNOWLEDGMENTS 

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 

 OE I-05-05-00 020 T E M P O R A RY MEDI C ARE - AP P R O VED DR U G DISC O U N T CA R D : ANALY S I S O F DRUG P R I CES 13