New York
Office of the New York State Comptroller, Division of State Government Accountability
Published April 5, 2023

Medicaid Program: Maximizing Drug Rebates Under the Federal Medicaid Drug Rebate Program

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Overall Conclusion

While the Department has made significant process improvements and system enhancements in the rebate collection process, certain weaknesses remain, resulting in $183.7 million in Medicaid drug rebates not invoiced during the audit period.

Source Document

Audit Scope

The audit covered the period from April 2018 through March 2022 and certain claims going back to January 2017.

Key Findings Summary

1

PACE claims: $12.8 million in rebates for Medicaid-only PACE recipients not previously included, eligible for rebates.

2

Uncollected Medicaid drug rebates totaling $183.7 million during the audit period due to errors and weaknesses in the rebate collection process.

3

Approximately $119 million in rebates were missed because of errors in the Department's claim extraction procedures (April 2018 through October 2020).

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AI-Assisted

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AI Scope Summary

Future Medicaid MDRP audits should build on these findings by strengthening data validation at claim extraction and crosswalk updates, ensuring complete NDC and unit reporting from all providers and MCOs (including PACE), implementing robust EIS edits and system checks to prevent missed rebates, and establishing formal retroactive invoicing procedures to recover rebates for claims processed during transitions.

AI-Generated Insight

The MDRP rebate program relies on accurate data flow across multiple systems (MDW, eMedNY, and Magellan) and timely, complete reporting of NDCs and procedure codes. The audit findings show that data quality, crosswalk maintenance, and contractor invoicing controls are critical levers to maximize rebates and reduce state costs; ongoing remediation and retroactive invoicing efforts are essential to recover unbilled rebates.