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Where To Report Waste
Fraud, Abuse, Or Retaliation
Where To Report Waste Fraud, Abuse, Or Retaliation

OWCP Did Not Ensure Best Prices and Allowed Inappropriate, Potentially Lethal Prescriptions in the FECA Program

Submitting OIG: 
Department of Labor OIG
Date Issued: 
Friday, March 31, 2023
Agency Reviewed / Investigated: 
Department of Labor
Submitting OIG-Specific Report Number: 
03-23-001-04-431
Location(s): 
Agency-Wide
Type of Report: 
Audit
Questioned Costs: 
$0
Funds for Better Use: 
$0
Number of Recommendations: 
10
View Document: 
AttachmentSize
PDF icon 03-23-001-04-431-OWCP-Did-Not-Ensure-Best-Prices-and-Allowed-Inappropriate-Potentially-Lethal.pdf3.7 MB
Additional Details Link: 
https://www.oig.dol.gov/public/reports/oa/2023/03-23-001-04-431.pdf

Related Open Recommendations

Recommendation Number Recommendation Status Significant Recommendation Additional Details
1 Open Yes
We recommend the Director of OWCP implement a process to ensure competitive prices for the FECA program by regularly evaluating alternate pricing methodologies and other sources — including state fee schedules, ACA FUL, NADAC, MAC lists, market research, and comparable payers — and updating its pricing methodology as appropriate.
2 Open Yes
We recommend the Director of OWCP implement a process to collect drug manufacturer rebates.
3 Open Yes
We recommend the Director of OWCP implement a process to review the effectiveness of policy changes, including: a. documented assessment of prescription information after any changes in the authorization, approval, and/or adjudication process to ensure desired changes are achieved; and b. documented solutions for any performance gaps identified during the review, including follow up testing.
4 Open Yes
We recommend the Director of OWCP implement an ongoing pharmaceutical monitoring and alert program to identify and closely monitor significant changes in costs, prescribing patterns, utilization, sources, and new and novel prescription drugs.
5 Open Yes
We recommend the Director of OWCP establish internal controls that identify prescription drugs payment and management issues in near-real-time, including: a. reviewing all system data fields provided by PBM(s) and bill pay vendor(s); b. determining any additional data fields/elements needed to monitor pharmaceutical spending and track trends over time; c. ensuring a recurring process to receive and immediately review data from the PBM(s) and bill pay vendor(s); and d. using that data review to report regularly to management, medical director, and staff pharmacists for collaborative identification of current and emerging issues.
6 Open Yes
We recommend the Director of OWCP implement a technology solution to perform ongoing prescription claim level reviews in near real-time - including contractual adherence by the PBM, prescription drug pricing discounts, and rebate guarantees - as well as to validate prescription drug pricing methodology.
7 Open Yes
We recommend the Director of OWCP adopt one or more of the widely used and thoroughly vetted evidence based clinical guidelines, such as those from the American College of Occupational and Environmental Medicine and Official Disability Guidelines, in place of treatment suites.
8 Open Yes
We recommend the Director of OWCP develop and deliver ongoing formal training for staff involved in making pharmaceutical decisions, with documentation of participation and post training evaluation.
9 Open Yes
We recommend the Director of OWCP add pharmacists and physicians to provide oversight of the FECA program for oversight and other necessary functions not assigned to the PBM.
10 Open Yes
We recommend the Director of OWCP ensure medical and pharmaceutical experts participate in the development, monitoring, maintenance, improvement, and evaluation of the FECA pharmaceutical program.
Displaying 10 of 10 Recommendations