Evidence record

Missouri Medicaid Rebates for Physician-Administered and Pharmacy Drugs

Jurisdiction
Missouri
Audit organization
Office of Inspector General, U.S. Department of Health and Human Services
Publication date
February 2026
Source record
Original document linked
Open original reportOriginal source available

Findings

6

Recommendations

6

Overall 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.

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.

Findings (6)

Each finding has a stable link.

  1. F-1218

    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.

  2. F-1219

    The State agency did not invoice rebates for $165,783 (Federal share) for other physician-administered drugs that could have been eligible for rebates.

  3. F-1220

    The State agency did not invoice for rebates on $14,489,535 ($9,510,305 Federal share) for single-source physician-administered drugs.

  4. F-1221

    The State agency did not invoice manufacturers for rebates on $311,551 ($204,564 Federal share) for top-20 multiple-source physician-administered drugs.

  5. F-1222

    The State agency did not collect rebates for $3,773,346 ($2,478,099 Federal share) for pharmacy drugs.

  6. F-1223

    The State agency did not implement previous audit recommendations.

Recommendations (6)

  1. R-1081

    Refund to the Federal Government $9,510,305 (Federal share) for claims for single-source physician-administered drugs that were ineligible for Federal reimbursement.

    Related finding F-1220
  2. R-1082

    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.

    Related finding F-1221
  3. R-1083

    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.

    Related finding F-1219
  4. R-1084

    Obtain rebates for the pharmacy drugs totaling $2,478,099 (Federal share), and refund the Federal share.

    Related finding F-1222
  5. R-1085

    Work with CMS to resolve all of the recommendations made in our previous audit report.

    Related finding F-1223
  6. R-1086

    Strengthen internal controls to ensure that all pharmacy and physician-administered drugs eligible for rebates are invoiced.

    Related finding F-1218