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in August of 2015 the Office of Inspector General was able to provide us a really good background on how to construct patient assistance program in a compliant manner thereamp;#39;s a couple of key initiatives associated with that oid opinion the first part was that the utilization of a non-commercial pharmacy for distribution of pap product was very essential to the compliant part of that program so the manufacturer really needs to be thinking about their SP network so when they develop their specialty pharmacy network they need to be not only thinking about whoamp;#39;s going to be involved in the commercial aspect of the distribution but also whoamp;#39;s going to be involved in a non-commercial distribution of that product which is the PAP pharmacy and typically you want to have some walls between those players so you donamp;#39;t necessarily want to have the same company who has a commercial pharmacy distributing the free drug product out of a potential other side of t
