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Another Doughnut Hole Dilemma - The Pros and Cons of Filling your Prescriptions Outside of Your Part D Plan

Category: The Donut Hole or Coverage Gap
Published: Aug, 17 2007 06:08:34


Doughnut Hole Question:

What can I do if I am approaching the doughnut hole?  Am I allowed to fill my prescriptions outside of my Part D plan?  If I did this, I would avoid the doughnut hole altogether by paying the full price through 2007 and get to 2008 before going into my plan’s coverage gap.

Answer:
You are not obligated to purchase your medications under your Medicare Part D program. However, if there is a chance to enter and come out of the Doughnut Hole or coverage gap, you may want to purchase your medications using your Part D card so that might be able to take advantage of the Catastrophic Coverage portion of your plan once you emerge out of the Doughnut Hole.

Please see our calculator to get an idea if/when you might emerge from the Doughnut hole for 2007: https://q1medicare.com/ DoughnutHole2007.php (also see: 2008, 2009, 2010 ).

In other words, the risk of purchasing medication "outside of Part D" is that there will be no record of these additional retail prescription costs. If you should have increased or unsuspected prescription costs later in the year, you may not be able to exit the Doughnut Hole and take advantage of the low cost Catastrophic Coverage.

You can see the parameters when you enter and exit the Doughnut Hole in the table here: https://q1medicare.com/2008 (also see: 2009, 2010).

Many Part D beneficiaries at a certain medication spending level are trying to thing about budgeting their money or, better said, strategic spending for prescriptions. Some people purchase a low-cost Part D plan to avoid any penalties and provide coverage if necessary.

At the same time, they may buy any needed medication from the lowest cost suppliers, even when outside of their chosen Part D plan. If they are confronted with unusual or unforeseen medication costs, they will go back under their Part D plan's coverage. Again the risk of missing Catastrophic Coverage must be weighed into the decision.

The Canadian Pharmacy Question

Many people are aware of the low cost medications available outside of the US and most people are also aware of the risks associated with non-US suppliers.  Naturally purchasing your medications from outside of the US does not count toward your Part D plan's Doughnut Hole.  Also a Washington Post article (written by Brian Krebs on June 14, 2005) noted that:

"Most Web sites that purport to sell quality, discounted prescription drugs from online stores in Canada appear to be controlled or owned by individuals or companies located outside Canada, including many in the United States, according to a study commissioned by the Food and Drug Administration.

The study examined some 11,000 Internet pharmacies, finding that only about a thousand of those Web sites actually sold prescription drugs and that fewer than 25 percent were registered to or hosted by companies or individuals in Canada.

Rather, the report concluded that most of the sites referred visitors to 1,009 online stores, 86 percent of which are currently hosted by companies located in the United States. Nearly 70 percent of the sites also were registered to U.S. citizens, and more than half of those sites are registered to a single Web design firm based in New England, which the publicly released version of the study did not identify.

Many of the apparently fraudulent sites referenced in the study were not reachable through traditional Internet search methods, said Tom McGinnis, director of pharmacy affairs for the FDA. Instead, most could only be found by clicking on links in junk 'spam' e-mails, he said." ...

"Cyveillance [the company doing the FDA's pharmacy research] also found many of the online pharmacy sites [nearly 80%] claiming to be based in Canada were actually registered to individuals or companies in other countries, such Australia, the Czech Republic, El Salvador, Germany, Mexico and Vietnam."

However, the article also adds:
"The FDA's McGinnis said the agency is not aware of any data suggesting that a single U.S. citizen has been harmed or killed by prescription drugs ordered from any legitimate Canadian pharmacy. Still, McGinnis said, as long as shipping medications into the United States remains illegal, the agency would continue to refuse to work with any entity supporting that activity. 'The FDA doesn't make the laws [on prescription drugs], it just enforces them, and we'll do whatever the law tells us to do.'"

Finally the legal issue surrounding Canadian prescriptions was nicely summarized on Wikipedia:

"The act of importation of any prescription drug (not necessarily a controlled substance) violates 21 USC, Section 301(aa) (http://www.fda.gov/opacom/laws/fdcact/fdcact3.htm), unless the following conditions are met (as listed in Section 804):

  1. The drug is imported from Canada, from a seller registered with the Secretary (i.e. with FDA);
  2. The drug is imported from a licensed pharmacy for personal use by an individual, not for resale, in quantities that do not exceed a 90-day supply;
  3. The drug is accompanied by a copy of a valid prescription;
  4. The drug is a prescription drug approved by the Secretary;
  5. The drug is in the form of a final finished dosage that was manufactured in an establishment registered under section 510; and
  6. The drug is imported under such other conditions as the Secretary determines to be necessary to ensure public safety."  (http://en.wikipedia.org/ wiki/Online_pharmacy)








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