Wells Fargo analyst David Maris explored Mylan's (NASDAQ: MYL) Epipen4Schools program. After reviewing the program he said it's "more complex than we thought". The way he described it it sounds eerily similar to what Valeant (NYSE: VRX) was doing with specialty pharmacy Philidor, although he didn't mention the Valeant comparison at all in his note.

First Maris notes that at the EpiPen4Schools.com webpage, Mylan's logo is displayed but also BioRidge Pharma.

They believe BioRidge Pharma is a specialty distribution company. Maris notes BioRidge Pharma seems to be running the EpiPen4Schools program, but it also appears that Mylan is the owner of the EpiPens4Schools.com domain. They also are uncertain whether BioRidge has any customers other than Mylan, and if so, if Mylan represents over 90% of BioRidge’s activities.

Maris also found another company with the same exact office address as BioRidge Pharma (200 Park Avenue, Suite 300, Florham Park, New Jersey), Asembia, which is a specialty distribution company.

The analyst said they tried repeatedly to reach BioRidge Pharma but were unable to discuss the company with management. They were also unable to find any mention of BioRidge or Asembia in Mylan’s most recent SEC filings.

In addition, Maris said it appears that neither Mylan, nor BioRidge, or Asembia ship EpiPens for the school program, but that two other designated pharmacies are responsible for the shipping.

Maris said they have the following questions for Mylan:

• What role does BioRidge Pharma play?
• Where are the costs of this program included?
• What role does Asembia play?
• Does Mylan own BioRidge and/or Asembia or provide either with any loans or other financial resources?
• Why does Mylan own the domain name?
• Are Asembia and BioRidge owned by the same individuals?
• Why is BioRidge a separate entity?
• What percentage of BioRidge’s activities and revenues are related to Mylan? Does Mylan have effective control of BioRidge?
• What role do Foundation Care Pharmacy and HD Smith play?
• What is the physical flow of product from Mylan to the schools?
• Who owns the EpiPen at the different stages?
• Are the free EpiPens accounted for as donations for tax purposes and if so, at what price?
• What is the cost of the products donated to date?
• What information does Mylan have access to that has been collected by BioRidge?
• Is the EpiPen4Schools program limited in duration? Was it established as a permanent program?
• Have there been any changes to the EpiPen4Schools program?
• Was the EpiPen4Schools program designed or implemented to further establish EpiPen with consumers?

The firm maintained a Market Perform rating and $43-$45 valuation range on Mylan.

For an analyst ratings summary and ratings history on Mylan click here. For more ratings news on Mylan click here.

Shares of Mylan closed at $43.03 yesterday.