On Oct. 10, 2018, two short federal laws took aim at a contract clause most patients had never heard of. The Know the Lowest Price Act1 and the Patient Right to Know Drug Prices Act2 barred drug plans from stopping pharmacists from telling customers when paying cash would cost less than using insurance.
For cheap generics, cash can win easily. The federal survey of pharmacy costs put the average acquisition cost of 30 generic lisinopril 10 mg tablets at about 54 cents in October 2026, based on a per-tablet rate of $0.01806 in CMS's NADAC data3. Any flat copay above a dollar or two is a multiple of that. Prescription discount cards live in the gap between what a pharmacy pays and what a patient is asked to pay.
Discount cards are free, need no enrollment, and turn up in doctors' offices, on websites and in mail inserts. The card itself is just a set of routing numbers. What sits behind it is a contract between the card's operator and a network of pharmacies, and that contract explains both when a card saves money and when it quietly costs something else, such as progress toward a Medicare out-of-pocket cap.
How a discount card claim works
A card operator, sometimes a pharmacy benefit manager and sometimes a marketing company that partners with one, signs agreements with pharmacies. Those agreements set the price the pharmacy will accept from cash-paying customers who present the card. At the counter, the pharmacy runs the card through the same claims system it uses for insurance, using the BIN, PCN and group numbers printed on it. The system returns the discounted price, and the customer pays that amount.
No insurer pays any part of the bill. The negotiated rate is the whole price.
Money to keep the card free generally comes from fees attached to each fill, which flow to the card operator and may be shared with whoever distributed the card. Those fees are invisible to the customer, and they are part of why the same drug can carry different prices on different cards at the same pharmacy. Our piece on why the same generic costs different amounts covers the other reasons prices diverge.
When a card tends to lower the price
Cards are most useful when insurance is not doing much for a particular fill: no drug coverage at all, a drug the plan does not cover, a high-deductible plan where the patient pays the full plan rate until the deductible is met, or an inexpensive generic whose negotiated cash price falls below a flat copay. Our guide to when the cash price beats the copay works through examples.
Finding out got easier with the 2018 laws. The Know the Lowest Price Act covers Medicare Part D and Medicare Advantage drug plans and, by its text, applies to "plan years beginning on or after January 1, 2020." The Patient Right to Know Drug Prices Act covers group health plans and insurers. A pharmacist may raise a lower cash price unprompted, and any customer can ask; GxRadar's guide to asking for the cash price and our script for talking to a pharmacist put the question into words.
Prices on cards vary a great deal from drug to drug and card to card, and the cheapest option on one prescription is often not the cheapest on the next.
How paying with a card compares
| Question | Insurance claim | Discount card | Cash, no card |
|---|---|---|---|
| Who sets the price | The plan's contract with the pharmacy | The card operator's contract with the pharmacy | The pharmacy's own cash price |
| Counts toward Medicare Part D deductible ($615 in 2026; $700 in 2027) | Yes, for covered drugs | No, when used instead of Part D | No |
| Counts toward Part D out-of-pocket cap ($2,100 in 2026; $2,400 in 2027) | Yes, for covered drugs | No, when used instead of Part D | No |
| Counts toward a commercial plan deductible | Yes, for covered drugs | Only if the plan accepts it | Only if the plan accepts it |
| Pharmacist may mention a lower cash price | Yes, under the 2018 laws | Not applicable | Not applicable |
| Main federal privacy framework | HIPAA | Often the FTC Act and Health Breach Notification Rule | HIPAA at the pharmacy |
Part D figures for 2026 come from CMS's 2026 rate announcement4 and the 2027 figures from its 2027 announcement5.
The deductible trade-off
A card purchase happens outside insurance, so the plan never sees it. Medicare's help-with-drug-costs page6 says discount cards "aren't considered creditable coverage," and that when they are used instead of a Medicare plan, the purchase does not count toward the Medicare deductible or out-of-pocket maximum. Medicare's fact sheet on 2027 changes7 repeats the point and applies it to a federal website that lists cash-price coupons as well as to private cards.
For someone with high drug costs, the rule has teeth. The Part D out-of-pocket cap is $2,100 in 2026 and rises to $2,400 in 2027. Spending routed through a card does not move a beneficiary toward that cap, so saving a few dollars on one fill can mean reaching the cap later in the year on everything else. The 2025 and 2026 benefit changes are covered in Medicare Part D changes.
Commercial plans differ. Each sets its own rule on whether a purchase made outside the plan can be credited, and many count only claims they process themselves. A plan's member services line or benefits documents will say which applies. A pharmacy generally runs a single fill through one route or the other, and for a covered drug to count toward plan limits it has to go through the plan.
Privacy rules for card apps
Buying through a discount card or its app can create a record of what someone takes, held outside the pharmacy. Many card operators and health apps are not HIPAA-covered entities, which puts them under a different federal rulebook enforced by the Federal Trade Commission, the Health Breach Notification Rule at 16 CFR Part 3188.
The FTC's 2024 final rule9, published in the Federal Register on May 30, 2024, and effective July 29, 2024, recounts the rule's enforcement history. In February 2023 the commission brought its first action under the rule, against a telehealth and prescription discount company it alleged had shared users' prescription medications and health conditions with advertising platforms. The settlement imposed injunctive relief and a $1.5 million civil penalty.
Changes finalized in 2024, announced in an April 2024 FTC press release10, make clear that an unauthorized disclosure of health data counts as a breach, alongside security intrusions. Companies must notify affected consumers "without unreasonable delay and in no case later than 60 calendar days" after discovering a breach. For breaches affecting 500 or more people, the FTC must now be told at the same time as consumers, and in some cases prominent media outlets must be notified. The FTC's business guidance11 says violators can face civil penalties of more than $50,000 per violation.
Card apps typically include privacy settings, some with options to limit marketing or data sharing, and many cards can be used at the counter without creating an online account. For anything about the medicine itself, including whether a different drug or strength makes sense, the person to ask is a pharmacist or prescriber; a script for talking to your pharmacist lists the price questions worth asking at the same visit.
Sources and notes
- Public Law 115-262 (2018). Know the Lowest Price Act of 2018
www.congress.gov/115/plaws/publ262/PLAW-115publ262.pdf - Public Law 115-263 (2018). Patient Right to Know Drug Prices Act
www.congress.gov/115/plaws/publ263/PLAW-115publ263.pdf - CMS (2026). NADAC (National Average Drug Acquisition Cost) 2026, data.medicaid.gov
data.medicaid.gov/dataset/fbb83258-11c7-47f5-8b18-5f8e79f7e704 - CMS (2025). Announcement of CY 2026 Medicare Advantage Capitation Rates and Part C and Part D Payment Policies
www.cms.gov/files/document/2026-announcement.pdf - CMS (2026). Announcement of CY 2027 Medicare Advantage Capitation Rates and Part C and Part D Payment Policies
www.cms.gov/files/document/2027-announcement.pdf - Medicare.gov (2026). Help with drug costs
www.medicare.gov/basics/costs/help/drug-costs - Medicare.gov (2026). Your Medicare in 2027: What's New and Changing (fact sheet)
www.medicare.gov/publications/12229-your-medicare-in-2027-whats-new-and-changing.pdf - Cornell LII (2026). 16 CFR Part 318, Health Breach Notification Rule
www.law.cornell.edu/cfr/text/16/part-318 - Federal Register (2024). Health Breach Notification Rule, final rule, 89 FR 47028
www.govinfo.gov/content/pkg/FR-2024-05-30/pdf/2024-10855.pdf - FTC (2024). FTC Finalizes Changes to the Health Breach Notification Rule
www.ftc.gov/news-events/news/press-releases/2024/04/ftc-finalizes-changes-health-breach-no - FTC (2024). Health Breach Notification Rule: The Basics for Business
www.ftc.gov/business-guidance/resources/health-breach-notification-rule-basics-business
Superscript numbers in the text link to these sources. GxRadar data (NADAC histories, recall and shortage counts) come from CMS and FDA files described on the sources page. Researched and drafted with AI assistance and checked against the sources above. Information current as of Nov 3, 2026 and may change. Spot an error? It will be corrected once confirmed.
Drug data in this article
Lisinopril 10 mg tabletCited by
How to compare pharmacy cash prices for a generic prescriptionWhy the same generic costs different amounts at different pharmaciesHigh-deductible health plans and generic drugsHow to ask for the cash price at the pharmacyPatient assistance programs, Extra Help and 340B, comparedMedicare Part D changes in 2025, 2026 and 2027Not health advice. GxRadar is for general information only. Nothing here is medical, pharmacy, legal or financial advice. Do not start, stop or change any medicine based on this site. Talk to your pharmacist or prescriber about your own situation. Laws, prices and program rules described here can change; confirm current details with the official source.