Alabama Did Not Always Invoice Rebates to Manufacturers for Pharmacy and Physician-Administered Drugs

Submitting OIG:

Department of Health & Human Services OIG

Date Issued:

Thursday, September 21, 2023

Agency Reviewed / Investigated:

Department of Health & Human Services

Submitting OIG-Specific Report Number:

A-04-21-08090

Component, if applicable:

Centers for Medicare & Medicaid Services

Centers for Medicare and Medicaid Services

External entity, if applicable:

Alabama Medicaid Agency

Location(s):

AL,

United States

Type of Report:

Audit

Questioned Costs:

$15,457,223

Funds for Better Use:

Number of Recommendations:

Report updated under NDAA 5274:

View Document:

Attachment	Size
42108090.pdf	2.72 MB

Recommendation Number	Recommendation Status	Significant Recommendation
23-A-04-118.01	Open	No
We recommend that the Alabama Medicaid Agency refund to the Federal Government $14,960,673 (Federal share) for claims for single-source physician-administered drugs that were ineligible for Federal reimbursement.
23-A-04-118.02	Open	No
We recommend that the Alabama Medicaid Agency refund to the Federal Government $43,981 (Federal share) for claims for top-20 multiple-source physician-administered drugs that were ineligible for Federal reimbursement.
23-A-04-118.03	Open	No
We recommend that the Alabama Medicaid Agency work with CMS to determine and refund the unallowable portion of $290,455 (Federal share) for other claims for multiple-source physician-administered drugs that may have been ineligible for Federal reimbursement and consider invoicing drug manufacturers for rebates for those drug claims that CMS determines are allowable.
23-A-04-118.04	Open	No
We recommend that the Alabama Medicaid Agency complete the process for rebating pharmacy drugs totaling $6,568 ($4,719 Federal share) for single-source and $219,220 ($157,395 Federal share) for multiple-source drugs that it had not previously collected a rebate on or refund the Federal share.
23-A-04-118.05	Open	No
We recommend that the Alabama Medicaid Agency work with CMS to determine and refund the unallowable portion of Federal reimbursement for physician-administered drugs that were not invoiced for rebates after December 31, 2019.
23-A-04-118.06	Open	No
We recommend that the Alabama Medicaid Agency strengthen its internal controls to ensure that all pharmacy and physician-administered drugs eligible for rebates are invoiced.

Recommendation Number

Recommendation Status

Significant Recommendation

Additional Details

23-A-04-118.01

Open

We recommend that the Alabama Medicaid Agency refund to the Federal Government $14,960,673 (Federal share) for claims for single-source physician-administered drugs that were ineligible for Federal reimbursement.

23-A-04-118.02

Open

We recommend that the Alabama Medicaid Agency refund to the Federal Government $43,981 (Federal share) for claims for top-20 multiple-source physician-administered drugs that were ineligible for Federal reimbursement.

23-A-04-118.03

Open