Missouri Medicaid Rebates for Physician-Administered and Pharmacy Drugs
Learn how the AI-generated research projects were createdOverall Conclusion
Although the State agency improved its controls over invoicing for rebates for physician-administered drugs, during our audit period the State agency did not comply with Federal Medicaid requirements for invoicing manufacturers for rebates for some physician-administered and pharmacy drugs.
Source Document
Audit Scope
Review of Missouri Department of Social Services, MO HealthNet's Medicaid rebates for physician-administered and pharmacy drugs for January 1, 2019 through December 31, 2022, including single-source and top-20 drugs, NDC data requirements, and CMS coordination.
Key Findings Summary
Between January 1, 2019, and December 31, 2022, Missouri did not invoice for, and collect from manufacturers, rebates for $9.7 million (Federal share) for physician-administered drugs and $2.5 million (Federal share) for pharmacy drugs.
The State agency did not invoice rebates for $165,783 (Federal share) for other physician-administered drugs that could have been eligible for rebates.
The State agency did not invoice for rebates on $14,489,535 ($9,510,305 Federal share) for single-source physician-administered drugs.
View the Findings tab to see all 6 findings
AI-Assisted
AI Scope Summary
Building on the objective to assess Missouri's compliance with Federal Medicaid rebate invoicing requirements, the audit examined whether the State agency accurately captured and invoiced rebates for physician-administered and pharmacy drugs during 2019–2022, including single-source and top-20 drugs, and whether prior audit recommendations were implemented; the findings indicate noncompliance in several areas, resulting in $14.8 million of rebates not invoiced and uncollected, characterized by missing NDC data, incomplete top-20 submission, and delays in corrective actions; the recommendations seek refunds, invoicing, and strengthened controls, with ongoing CMS coordination.
AI-Generated Insight
This audit highlights ongoing challenges in capturing and invoicing Medicaid drug rebates in Missouri, including incomplete data submission (NDCs and Top-20 data), delays in implementing prior recommendations, and the need for stronger internal controls and CMS coordination to ensure rebates are properly invoiced and refunded.
Audit Objectives
Our objective was to determine whether the State agency complied with Federal Medicaid requirements for invoicing manufacturers for rebates for physician-administered and pharmacy drugs.
Audit Findings (6)
Between January 1, 2019, and December 31, 2022, Missouri did not invoice for, and collect from manufacturers, rebates for $9.7 million (Federal share) for physician-administered drugs and $2.5 million (Federal share) for pharmacy drugs.
The State agency did not invoice rebates for $165,783 (Federal share) for other physician-administered drugs that could have been eligible for rebates.
The State agency did not invoice for rebates on $14,489,535 ($9,510,305 Federal share) for single-source physician-administered drugs.
The State agency did not invoice manufacturers for rebates on $311,551 ($204,564 Federal share) for top-20 multiple-source physician-administered drugs.
The State agency did not collect rebates for $3,773,346 ($2,478,099 Federal share) for pharmacy drugs.
The State agency did not implement previous audit recommendations.
Recommendations (6)
Refund to the Federal Government $9,510,305 (Federal share) for claims for single-source physician-administered drugs that were ineligible for Federal reimbursement.
Refund to the Federal Government $204,564 (Federal share) for claims for top-20 multiple-source physician-administered drugs that were ineligible for Federal reimbursement.
Work with CMS to determine the unallowable portion of $165,783 (Federal share) for claims for other physician-administered drugs that may have been required to be invoiced, and invoice drug manufacturers for rebates for those drugs.
Obtain rebates for the pharmacy drugs totaling $2,478,099 (Federal share), and refund the Federal share.
Work with CMS to resolve all of the recommendations made in our previous audit report.
Strengthen internal controls to ensure that all pharmacy and physician-administered drugs eligible for rebates are invoiced.