The OIG stance is typically government: make a straightforward program that works well in the private sector a cumbersome and daunting process that discourages consumer participation and then makes any corporate deviation from the regulations or their interpetation by Asst. US attorneys or self-styled consumer groups grounds for criminal investigation or litigation.
Which goes to show you what life would be like if the government took direct control of the Medicare drug benefit….bad enough the nit-wits in OIG have screwed this one act of charity up…what would happen if every part of the pharmaceutical business was under government control?