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Medicaid audit topic guide

Rebates

Definition

Medicaid drug rebates reduce prescription-drug costs through amounts owed by manufacturers under federal and supplemental agreements. Audits examine invoicing, collection, dispute resolution, reconciliation, and the accuracy of utilization data used to calculate rebates.

Why auditors care

Missed, delayed, or incorrectly calculated rebates increase the net cost of Medicaid pharmacy benefits. Effective controls must connect claims data, manufacturer invoices, collections, and unresolved disputes so that every amount owed can be identified and recovered.

Evidence coverage

Reports
11
States represented
6
Publishing agencies
9
Publication period
2018–2026

State coverage reflects each report’s recorded jurisdiction.

Supporting findings

14 findings

  1. Molina did not consistently submit dental value-added services encounters with the correct financial arrangement code. 13,654 of 23,303 encounters (59%) were coded as payable dental services (financial arrangement code 04) instead of value-added services (financial arrangement code 11), totaling $560,777.

    Dental Value-Added Services—Molina HealthcareTexas Health and Human Services Office of Inspector GeneralFeb 20, 2026

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

    Missouri Medicaid Rebates for Physician-Administered and Pharmacy DrugsOffice of Inspector General, U.S. Department of Health and Human ServicesFeb 2026

  3. The State agency did not invoice for, and collect from manufacturers, estimated rebates totaling $8.2 million ($6.1 million Federal share) for physician-administered drugs dispensed to MCO enrollees.

    West Virginia Medicaid Managed-Care Rebates Associated With Physician-Administered DrugsOffice of Inspector General, U.S. Department of Health and Human ServicesFeb 2026

Recommendations

13 recommendations

  1. Implement a pass-through pricing model by default, ensuring all rebates and cost savings are passed through to CCOs and Medicaid.

    Poor Accountability and Transparency Harm Medicaid Patients and Independent PharmaciesOregon Secretary of State, Audits DivisionAug 2023

  2. Review its state fiscal year 2023, 2024, and 2025 FSRs to determine whether any reported dental value-added services expenses were included in the medical expenses.

    Dental Value-Added Services—Molina HealthcareTexas Health and Human Services Office of Inspector GeneralFeb 20, 2026

  3. Refund to the Federal Government $6,055,786 (Federal share) for claims for single-source physician-administered drugs that were ineligible for Federal reimbursement.

    West Virginia Medicaid Managed-Care Rebates Associated With Physician-Administered DrugsOffice of Inspector General, U.S. Department of Health and Human ServicesFeb 2026