Michigan
Michigan Office of the Auditor General
Published March 25, 2026

Efforts to Monitor Established Service Level Agreements for the Medicaid Pharmacy Benefits Manager Contract

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Overall Conclusion

Not sufficient.

Source Document

Audit Scope

To examine records and processes related to MDHHS's efforts to monitor SLAs identified in the Medicaid PBM contract, covering October 1, 2023 through June 30, 2025.

Key Findings Summary

1

Significant improvement needed in MDHHS's PBM contract monitoring plan and written monitoring procedures for contract SLAs.

2

Performance and documentation of monitoring activities over the contractor's compliance with SLAs needs significant improvement.

AI-Assisted

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AI Scope Summary

This performance audit evaluated how MDHHS monitors SLAs in the Medicaid PBM contract, assessing the adequacy of the contract monitoring plan, the existence of written monitoring procedures, the sufficiency of monitoring activities, and the timeliness and completeness of documentation, with a conclusion that MDHHS' monitoring efforts were not sufficient, and recommendations to strengthen controls and documentation for future procurements.

AI-Generated Insight

The audit identifies material weaknesses in MDHHS PBM contract oversight, including outdated monitoring plans, lack of documented monitoring procedures, and absence of independent verification of contractor-reported SLA compliance, highlighting risks to public funds and service quality in the Medicaid PBM program.

Audit Objectives

1

To assess the sufficiency of MDHHS's efforts to monitor SLAs established in the Medicaid PBM contract.

Audit Findings (2)

1

Significant improvement needed in MDHHS's PBM contract monitoring plan and written monitoring procedures for contract SLAs.

2

Performance and documentation of monitoring activities over the contractor's compliance with SLAs needs significant improvement.

Recommendations (3)

1

MDHHS significantly improve its contract monitoring plan regarding SLAs for the PBM contract.

2

MDHHS establish written policies and/or procedures for monitoring PBM contract SLAs.

3

MDHHS significantly improve its performance and documentation of monitoring of the PBM contractor's compliance with SLAs.