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Cubanski Web Exclusive
D A T A W A T C H D R U G C A R D S W E B E X C L U S I V E
14 April 2004
Savings From Drug Discount Cards: Relief For Medicare Beneficiaries?
Discount card savings will not
completely alleviate the burden
of drug spending for heavy users of medications.
By Juliette Cubanski, Richard
G. Frank, and Arnold M. Epstein
ABSTRACT:
Beginning in mid-2004, Medicare beneficiaries can enroll in prescription drug
discount card programs approved by the federal government. We estimate modest
savings for beneficiaries without drug coverage from existing drug discount
card programs, with average savings of 17.4 percent over current retail prices.
Although estimated percentage savings are greater on generics than brand-name
drugs, estimated absolute dollar savings are greater for brands. Medicare-approved
discount card savings for individual beneficiaries will depend on current out-of-pocket
drug spending, the number and types of drugs used, and specific card program
features. Aggregate savings estimates vary widely, based on uncertainty in discounts
and program participation rates.
High out-of-pocket prescription drug spending by Medicare beneficiaries without
drug coverage has been a long-standing policy concern. Approximately one-quarter
of beneficiaries pay for drugs entirely out of pocket for the entire year, and
a larger proportion for part of the year.1 Beneficiaries
without drug coverage spend more out of pocket and fill fewer prescriptions
than their peers with drug coverage.2 They also
face the highest retail drug prices.3
The Medicare Prescription Drug, Improvement, and Modernization Act (MMA) of
2003 (P.L. 108-173) establishes a Medicare Prescription Drug Discount Card and
Transitional Assistance Program to provide temporary assistance to beneficiaries
with prescription drug costs before Medicare-sponsored drug coverage begins
in 2006.4 Discount cards may offer consumers lower
drug prices by reducing pharmacy dispensing fees, using less costly outlets
such as the Internet and mail order, and negotiating discounts from pharmacies
and drug makers.
Beginning in mid-2004, beneficiaries can enroll in federally approved, voluntary
prescription drug discount card programs. Certain low-income enrollees will
receive $600 to use in conjunction with the discount card. The maximum allowed
annual enrollment fee is $30. Medicares approval of discount card programs
is expected to promote enrollment in approved programs and strengthen their
ability to negotiate discounts. The Centers for Medicare and Medicaid Services
(CMS) reported in March 2004 that twenty-eight companies have received federal
approval to provide drug discount cards.5 The program
will terminate in 2006, when full Medicare-sponsored drug coverage begins.
Perhaps the most important question about Medicare-approved drug discount cards
is their ability to deliver savings to enrollees. The law does not require any
minimum discount. The CMS states that use of such cards could yield savings
of 1015 percent on total drug spending and up to 25 percent on some drugs.6
The source of these estimates is not specified. Estimates of savings from existing
discount card programs vary, because of differences in data sources and estimation
methodologies.7 In this paper we estimate what out-of-pocket
prescription drug savings might be under the Medicare-approved program for beneficiaries
and subgroups of beneficiaries without drug coverage, using beneficiaries
self-reported drug spending data. We demonstrate how discount card use might
differentially affect out-of-pocket spending on different types of drugs (generics
and brands). Finally, we illustrate how varying assumptions about percentage
discounts, based on the experience of existing programs, and levels of participation
in the Medicare-approved card program affect aggregate savings estimates. Our
analysis seeks to contribute to the assessment of potential impacts of the Medicare
prescription drug discount card program that begins in June 2004.
Study Data And Methods
We estimated savings for beneficiaries from discount cards in three stages.
First, we estimated average discounts for each of sixty-one high-volume prescription
drugs (forty-nine brand-name and twelve generic) offered by seven existing card
programs (Exhibit
1).8 We identified drugs that were market leaders
in fourteen therapeutic categories in 2000 and also frequently used by the elderly
in 1999 and 2000.9 The seven programs, none sponsored
by drug companies, were chosen because they provided drug prices on the Internet
and because they appear to meet most of the qualifications for Medicare approval.
We calculated the average discount for each drug by comparing the average of
the seven card program prices to average retail price estimates for cash payers
for each selected brand-name or generic drug. Retail prices were measured in
terms of the average wholesale price (AWP).10 To
derive these estimates, we reviewed the research and trade literatures on pharmaceutical
retail pricing and conducted an independent analysis of retail prices offered
by a sample of eight chain and independent pharmacies in Boston, Massachusetts,
and Lincoln, Nebraska. Our research indicates that retail drug prices vary widely
across location, time, and type of pharmacy and are generally higher than AWP
for brand-name drugs and lower than AWP for generics.11
We compiled a range of three retail price estimates for each selected brand-name
drug (AWP plus 4 percent, 7 percent, and 15 percent) and two for each selected
generic drug (AWP minus 14 percent and 36 percent) against which to compare
average discount card prices. In our final analysis, we used AWP minus 36 percent
as a lower-bound estimate of generic retail prices, along with AWP plus 7 percent
as the midpoint estimate of brand-name retail prices. Finally, we calculated
the average discount rate across all drugs and all programs, as well as averages
for subcategories of generic and brand-name drugs.
In the second stage, we analyzed prescription drug spending and use patterns
reported by Medicare beneficiaries without drug coverage, based on calendar
year 2000 data from the Medicare Current Beneficiary Survey (MCBS) Cost and
Use file.12 We analyzed data for noninstitutionalized
elderly and disabled beneficiaries without drug coverage for the entire year
(sample N = 2,903; weighted N = 9.2 million), half of whom used at least one
sample drug in 2000 (sample n = 1,526; weighted n = 4.5 million).13
This analysis provided a baseline for estimating changes in out-of-pocket spending
from drug discount cards.
In the third stage, we estimated expected out-of-pocket savings stemming from
discount card use by beneficiaries without drug coverage. We applied our estimated
average discount rate for each sample drug to out-of-pocket spending on the
drug reported by noncovered beneficiaries in 2000. We then estimated average
percentage and absolute savings for beneficiary subgroups, defined by sex, age,
self-reported health status, metropolitan status, race/ethnicity, income, and
supplemental insurance coverage. We also estimated savings for those using generic
and brand-name drugs and drugs in different therapeutic categories.
We then extrapolated from our estimated rates of discount card savings on sample
drugs, to estimate individual and aggregate savings on all drugs by all Medicare
beneficiaries without drug coverage. To extrapolate, we applied the average
percentage savings that we estimated for subgroups of noncovered sample drug
users to spending on all drugs by all noncovered beneficiaries in these subgroups.
For example, we found that sample low-income beneficiaries without coverage
would save 17.7 percent on their out-of-pocket spending on sample drugs. To
estimate savings for all noncovered low-income beneficiaries, we multiplied
their out-of-pocket spending amount on all drugs by this savings estimate. Finally,
we estimated a range of potential aggregate savings based on uncertainty in
discounts that might be offered, the types of beneficiaries who might be most
likely to participate, and the percentage of beneficiaries who might enroll.
Study Results
Average savings per beneficiary
in 2000. Drug
discount cards could save beneficiaries an average of 17.4 percent on their
out-of-pocket spending for sample drugs (Exhibit
1). According to our analysis of 2000 MCBS data, average out-of-pocket spending
on all drugs by all noncovered beneficiaries was $672. Applying the 17.4 percent
estimate of average savings on sample drugs to average out-of-pocket spending
on all drugs, we estimated that average savings per beneficiary in 2000 could
be $117 (Exhibit
2). This estimate, however, does not factor in program enrollment fees or
any drug utilization changes in response to reduced retail prices.
Savings by type of drug.
We estimated larger discount card savings for generic drugs (41 percent) than
for brand-name drugs (14 percent) (Exhibit
1). Because brand-name drugs accounted for 88 percent of out-of-pocket drug
spending in 2000, however, estimated out-of-pocket dollar savings from discount
cards would be largely composed of savings on brands ($83 out of $117) (Exhibit
3). Our estimates of average discounts by drug type across the seven card
programs in our analysis are the midpoints in a wide range of available discounts.
Across these programs, the average generic drug discount, compared with our
retail price estimate, ranged from a low of 18.3 percent to a high of 47.2 percent,
whereas discounts for brand-name drugs ranged from 9.5 percent to 17.0 percent.
Savings for beneficiary subgroups.
Estimated savings for different beneficiary subgroups varied slightly around
the mean rate of 17.4 percent, based on observed differences in drug use patterns,
including average number of prescriptions filled and types of drugs used (Exhibit
2). Thus, we estimated different dollar savings from discount card use for
different subgroups of beneficiaries. For example, noncovered beneficiaries
in poor health would save, on average, an estimated $176 out of $999 in out-of-pocket
drug spending in 2000, compared with $62 in estimated savings out of $358 in
spending for those in excellent health. These results are not surprising, because
those who spend more generally can expect greater savings from discount cards.
Savings from Medicare-approved programs might not be directly related to spending,
however, since discounts likely will not be offered on all drugs.
Low-income beneficiaries without drug coverage face particular challenges affording
medications. In 2000 approximately two million beneficiaries with very low incomes
($10,000 or less) lacked drug coverage.14 We observed
lower out-of-pocket drug spending among noncovered low-income beneficiaries
and therefore estimated lower discount card savings for them than for noncovered
beneficiaries with higher incomes (Exhibit
2). For example, compared with people whose self-reported incomes were $40,000
or more, estimated out-of-pocket savings from discount cards were approximately
30 percent lower for low-income beneficiaries in 2000.15
Among noncovered beneficiaries, differences in out-of-pocket drug spending across
income groups appear to be driven more by differences in types of drugs used
than in number of prescriptions filled. Both lower-income and higher-income
beneficiaries without drug coverage reported filling approximately eighteen
prescriptions in 2000. Yet a higher rate of savings from discount card use17.7
percent for the lowest-income beneficiaries versus 16.7 percent for those with
incomes greater than $40,000suggests that low-income beneficiaries used
a less costly mix of sample drugsthat is, more generic drugs and fewer
high-cost brand-name drugs.
For some beneficiaries without drug coverage, out-of-pocket drug spending represents
a large share of income. We estimated that discount card savings could greatly
reduce this spending. On average, out-of-pocket drug spending was 5.1 percent
of income for noncovered beneficiaries in 2000; their estimated average savings
from discount cards would have equaled 0.9 percent of their income (Exhibit
4). Relative to income, we estimated greater savings for low-income than
for higher-income beneficiaries. The lowest-income beneficiaries without drug
coverage, whose out-of-pocket drug expenses were 10 percent of income in 2000,
would save an average of 1.8 percent of income from discount cards. This estimate
is nine times greater than income-related discount card savings for beneficiaries
with incomes above $40,000.
Discount card use notwithstanding, the financial burden of drug costs could
remain substantial for noncovered beneficiaries who incur high out-of-pocket
costs. Among beneficiaries without drug coverage who filled a prescription in
2000 (7.6 million beneficiaries, or 83 percent of noncovered beneficiaries),
the highest-spending 10 percent paid $1,874 or more out of pocket. Average out-of-pocket
spending per beneficiary in this top decile was $2,829, which was 3.5 times
more than average spending by beneficiaries who filled a prescription in 2000
($806). Even with average savings of 17.4 percent, or $481, the highest-spending
beneficiaries without drug coverage would still face an average total drug bill
of $2,348, or 7 percent of their income.
Aggregate savings for beneficiaries without drug coverage.
Total out-of-pocket drug spending by all Medicare beneficiaries without drug
coverage in 2000 was $6.2 billion. Estimating total discount card savings of
$1 billion ($6.2 billion multiplied by the estimated 17.4 average percent savings)
could overstate the actual impact, given uncertainty in discounts that will
be offered and in the number and types of beneficiaries who will enroll in Medicare-approved
card programs. To gauge the potential impact of these factors, we estimated
aggregate savings using a range of overall discounts: the average across all
programs in our analysis (17.4 percent) and the averages from programs offering
the lowest (12 percent) and highest (23 percent) average discounts on our sample
drugs. We then estimated individual and aggregate savings using these three
discount rates for subgroups of beneficiaries who might be most likely to enroll
in Medicare-approved programs, including those with low incomes and those with
the highest out-of-pocket drug costs, assuming that all of these beneficiaries
would enroll. Then, relaxing the assumption of full participation among these
subgroups, we estimated savings for all beneficiaries without drug coverage
based on three different estimates of overall participation: a 10 percent lower
boundary based on a Congressional Budget Office (CBO) enrollment projection,
a 75 percent upper boundary based on an estimate from the Bush administration,
and a 50 percent midrange estimate.16
Not surprisingly, our results demonstrate that varying assumptions about discount
rates and the number and types of beneficiaries who might enroll produce much
uncertainty about the magnitude of individual and aggregate savings (Exhibit
5). Out-of-pocket dollar savings vary widely around the average 17.4 percent
estimate. For example, we estimated that if 10 percent of all noncovered beneficiaries
enrolled in drug card programs and received an average 12 percent discount,
aggregate out-of-pocket savings would have totaled only $74 million in 2000.
On the other hand, if 75 percent of noncovered beneficiaries enrolled and received
average discounts as high as 23 percent, out-of-pocket savings would have been
an estimated $1 billion. The wide range in these numbers indicates that any
single estimate of the potential economic impact of the Medicare-approved discount
card program is subject to substantial uncertainty, even after actual program
enrollment figures are known.
Discussion
Implications for the Medicare
Prescription Drug Discount Card Program.
Our results suggest that until Medicare Part D drug coverage begins in 2006,
drug discount cards could provide modest financial relief for Medicare beneficiaries
without drug coverage who face high out-of-pocket drug spending. For low-income
beneficiaries, discount card savings appear less meaningful when measured in
absolute dollar amounts than when measured as a percentage of their income saved.
The $600 subsidy provided to low-income beneficiaries who enroll in Medicare-approved
programs will increase the savings for these beneficiaries.
As our analysis suggests, individual savings from Medicare-approved discount
cards will depend on many factors, including the number, type, and duration
of medications taken; initial out-of-pocket drug costs; where prescriptions
are filled; discounts offered on drugs consumed; and retail or mail-order prices
that would otherwise have been paid. Medicare beneficiaries can now enroll in
multiple discount card programs, but as of June 2004 enrollment will be limited
to one Medicare-approved program at a time.17 The
CMS will provide comparative information about Medicare-approved cards to help
beneficiaries identify which one best meets their needs. Choosing optimally
will require a careful assessment by all beneficiaries to estimate their potential
savings. While enrollees will have one opportunity to switch programs between
2004 and 2005, drug prices offered by each program can change weekly. Thus,
a beneficiarys initial optimal selection might not remain the best choice
throughout the year.
Whether Medicares endorsement and the enrollment exclusivity provision
will generate larger discounts than existing programs offer or will serve primarily
to increase enrollment in Medicare-approved programs without appreciably affecting
price discounts is unknown at this time. Also unknown are the actual rate of
savings that Medicare-approved discount cards will offer, the rate of participation
in these programs, and retail drug prices beneficiaries would otherwise pay.
Together, these unknowns generate wide-ranging estimates of aggregate discount
card savings that could accrue to Medicare beneficiaries, as our analysis shows.
Study limitations.
Our analysis has some important limitations. Our savings estimates are sensitive
to the composition of the drug sample, selection of current discount card programs,
and estimates of retail drug prices. Our drug sample consisted of a three-to-one
ratio of brand-name to generic drugs, and some therapeutic categories contained
multiple generics, whereas others had none. Therefore, our estimate of average
generic savings could be less reliable than the brand-name savings estimate.
Retail drug pricing involves complex negotiations among drug makers, wholesalers,
purchasers, and pharmacies. A point estimate of average retail prices is subject
to some uncertainty, and we cannot know how representative our estimates are
of actual retail prices. Nevertheless, although we acknowledge the sensitivity
of our analysis to these factors, our overall results on average discount card
savings are consistent in magnitude and direction with previous estimates.18
Our savings estimates apply to beneficiaries without drug coverage, assuming
that they all pay nondiscounted retail prices now. A small but unknown share
already use discount cards or receive senior discounts from pharmacies. Beneficiaries
were not asked about discount card use in the 2000 MCBS, although the CMS has
begun probing the data to identify insurance plans that could be discount cards.19
Our retail price estimates do not factor in discounts that some pharmacies give
elderly customers, since not all pharmacies in our retail price survey offered
such discounts. Accounting for this would reduce our estimates of both average
retail prices faced by beneficiaries and discount card savings.
Extrapolating from sample drugs to all drugs and from sample drug users to all
noncovered beneficiaries allows us to illustrate the potential impact of the
Medicare discount card program in various ways. However, it introduces another
element of uncertainty in our analysis. We assumed that average discounts would
be the same for all drugs taken by all beneficiaries in each subgroup as they
were for sample drugs taken by sample beneficiaries. We cannot verify the accuracy
of this assumption to assess how our estimates might be biased.
Our estimates are based on beneficiaries out-of-pocket drug spending patterns
in 2000, although the Medicare discount card program begins in mid-2004. Thus,
estimated individual and aggregate dollar savings do not reflect current or
future dollar savings. Higher drug spending would affect our estimates of discount
card savings in absolute dollars but not in percentages. The CMS has projected
that Medicare beneficiaries without drug coverage will face, on average, $1,400
in out-of-pocket drug costs in 2004.20 Applying
our estimated average discount card savings of 17.4 percent, out-of-pocket savings
per beneficiary would average $238 in 2004, compared with the $117 in savings
we estimated for 2000.
Conclusions
Our results indicate that prescription drug discount cards could modestly reduce
Medicare beneficiaries out-of-pocket drug spending before expanded Medicare
drug coverage begins in 2006. However, the wide variation in individual and
aggregate savings that we estimated demonstrates the uncertainty in assessing
the overall value of the program to Medicare beneficiaries. Those who now lack
prescription drug coverage and who incur large out-of-pocket costs likely will
see some relief but still face sizable out-of-pocket costs. Moreover, discount
card savings will not completely alleviate the burden of drug spending for heavy
users of medication, especially higher-priced brand-name drugs. Low-income beneficiaries
who use a Medicare-approved drug card, however, will almost certainly benefit,
in part because of the $600 subsidy. They also could see the largest reductions
in out-of-pocket drug spending relative to their income. Further research is
needed to monitor the Medicare Prescription Drug Discount Card Program and the
savings that accrue to beneficiaries who enroll.
The authors gratefully acknowledge grant support from the Henry J. Kaiser
Family Foundation. They thank Patricia Neuman, Kristina Hanson, Katherine Swartz,
the editors, and two anonymous reviewers for valuable comments and suggestions
on earlier drafts of this manuscript, and Chapin White for technical assistance.
Juliette Cubanski gratefully acknowledges funding from the National Institute
on Aging, through Grant no. T32-AG00186 to the National Bureau of Economic Research.
NOTES
1. M. Laschober et al., Trends in Medicare Supplemental
Insurance and Prescription Drug Coverage, 19961999, Health Affairs,
27 February 2002, content.healthaffairs.org/cgi/content/abstract/hlthaff.w2.127
(8 October 2003); and Henry J. Kaiser Family Foundation, Medicare and Prescription
Drugs (Washington: Kaiser Family Foundation, April 2003).
2. Centers for Medicare and Medicaid Services, Program Information
on Medicare, Medicaid, SCHIP, and Other Programs of CMS, June 2002, www.cms.hhs.gov/charts/series/allcharts.pdf
(26 February 2004).
3. Office of the Assistant Secretary for Planning and Evaluation,
U.S. Department of Health and Human Services, Report to the President: Prescription
Drug Coverage, Spending, Utilization, and Prices (Washington: ASPE, May
2000); and R.G. Frank, Prescription Drug Prices: Why Do Some Pay More
than Others Do? Health Affairs 20, no. 2 (2001): 115128.
4. The CMS issued regulations for the Medicare discount card
program 10 December 2003. See CMS, Interim Final Rule with Comment Period,
www.cms.hhs.gov/discountdrugs/rxcard_interimrule.pdf
(13 December 2003).
5. HHS Gives Seal of Approval to Medicare Drug Discount
Cards, 25 March 2004, www.cms.hhs.gov/media/press/release.asp?Counter=988
(29 March 2004).
6. CMS, Overview: Medicare Prescription Drug Discount
Card and Transitional Assistance Program, www.cms.hhs.gov/discountdrugs/overview.asp
(13 December 2003).
7. U.S. General Accounting Office, Prescription Drugs: Prices
Available through Discount Cards and from Other Sources, Pub. no. GAO-02-280R
(Washington: GAO, 5 December 2001); C.P. Thomas et al., PBM-Administered
Prescription Drug Discount Cards: Savings for Uninsured Seniors, 11 March
2003, sihp.brandeis.edu/News/Brandeis%20Savings%20for%20Uninsured%20Seniors%20Final4.pdf
(24 March 2004); and GAO, Prescription Drug Discount Cards: Savings Depend
on Pharmacy and Type of Card Used, Pub. no. GAO-03-912 (Washington: GAO,
September 2003).
8. The programs in our analysis (and sponsoring entities) were
MembeRx Choice (AARP), Prescription Plus (Care Entrée), MagnaCard (Senior
Insurance Online), MHRx (MemberHealth Inc.), RxDrugCard (RxDrugCard.com),
SaveWell (SaveWell), and YOURxPLAN (Medco Health).
9. National Institute for Health Care Management, Prescription
Drug Expenditures in 2001: Another Year of Escalating Costs (Washington:
NIHCM Foundation, 29 March 2002); CMS, Medicare-Endorsed Prescription Drug
Card Assistance Initiative Solicitation for Applications (Washington: CMS,
7 January 2003), 58; and Families USA, Bitter Pill: The Rising Prices of
Prescription Drugs for Older Americans (Washington: Families USA, June 2002).
10. Our source for AWP data was Medical Economics Staff, Red
Book (Montvale, N.J.: Thomson Medical Economics, 2002). Existing cards often
advertise savings relative to AWP, which is based on pricing data from pharmaceutical
manufacturers, distributors, and other suppliers.
11. See, for example, GAO, Prescription Drug Pricing: Implications
for Retail Pharmacies, Pub. no. GAO/T-HEHS-96-216 (Washington: GAO, 19 September
1996); ASPE, Report to the President; and GAO, Prescription Drug Discount
Cards.
12. While some research suggests that self-reporting tends
to underestimate drug use and spending, our analysis follows that of John Poisal
and colleagues in not adjusting these figures, assuming that underreporting
is randomly distributed. J.A. Poisal and L. Murray, Growing Differences
between Medicare Beneficiaries with and without Drug Coverage, Health
Affairs 20, no. 2 (2001): 7485. To the extent that MCBS respondents
underreport drug use and spending, our savings estimates are equivalently low.
13. We used the CMS algorithm to identify sources and rates
of supplemental insurance and drug coverage; ibid. No prescriptions were reported
in the 2000 MCBS for one of the sample generic drugs. Spending on the remaining
sixty sample drugs was 35 percent of all drug spending reported in 2000; 79
percent of total drug spending was for drugs in therapeutic categories that
included sample drugs.
14. Median gross income for these beneficiaries was $7,716
(versus $20,400 for noncovered beneficiaries overall), which fell below 100
percent of the federal poverty level for an elderly person in 2000. In 2000,
100 percent of poverty was $8,259 for an elderly individual and $10,419 for
an elderly couple.
15. Estimates do not factor in the $600 low-income subsidy.
16. Congressional Budget Office, Cost Estimate: H.R.1 Medicare
Prescription Drug and Modernization Act of 2003 and S.1 Prescription Drug and
Medicare Improvement Act of 2003, 22 July 2003, ftp.cbo.gov/44xx/doc4438/hr1s1.pdf
(8 October 2003); and CMS, Medicare Endorsed Prescription Drug Card and
Drug Discount Card Assistance Initiative; Proposed Rule, Federal Register
67, no. 44 (6 March 2002): 1067610296.
17. Enrolling in multiple nonendorsed programs is permitted,
although it is unclear how the availability of Medicare-approved cards will
affect existing programs.
18. The GAO reported discounts of 8.2 percent for brand-name
drugs and 36.8 percent for generics. GAO, Prescription Drugs. Cindy Parks
Thomas and colleagues reported average discounts of 15 percent overall, 26 percent
for generics, and 14 percent for brand-name drugs. Thomas et al., PBM-Administered
Prescription Drug Discount Cards.
19. CMS, An Update on the Medicare Current Beneficiary
Survey (Presentation at AcademyHealth Annual Meeting, Nashville, Tennessee,
June 2003).
20. CMS, Overview: Medicare Prescription Drug Discount
Card.
Juliette Cubanski
(cubanski{at}hcp.med.harvard.edu)
is a doctoral candidate in the Program in Health Policy, Harvard University,
in Boston, Massachusetts. Richard Frank is the Margaret T. Morris Professor
of Health Economics, Harvard Medical School. Arnold Epstein is the John H. Foster
Professor of Health Policy and Management, Harvard School of Public Health.
DOI: 10.1377/hlthaff.W4.198
©2004 Project HOPEThe People-to-People Health Foundation, Inc.
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