Audit of the Reasonableness of Selected FEHBP Carriers' Pharmacy Benefit Contracts

Submitting OIG:

Office of Personnel Management OIG

Date Issued:

Thursday, July 29, 2021

Agency Reviewed / Investigated:

Office of Personnel Management

Submitting OIG-Specific Report Number:

1H-99-00-20-016

Component, if applicable:

Federal Employees Health Benefits Program

External entity, if applicable:

BlueCross BlueShield Association; Government Employees Health Association; Mail Handlers Benefit Plan; National Association of Letter Carriers; National Rural Letter Carriers' Association

Location(s):

Agency-Wide

Type of Report:

Audit

Questioned Costs:

Funds for Better Use:

Number of Recommendations:

View Document:

Attachment	Size
1H-99-00-20-016.PDF	1.71 MB

Recommendation Number	Recommendation Status	Significant Recommendation
1	Open	Yes
We recommend that the Contracting Officer direct its carriers to consider pooling their resources into a common PBM agreement, which could potentially not only lower costs to the program but also to its Federal members.
2	Open	Yes
We recommend that the Contracting Officer complete a data analysis of the claims pricing for all FEHBP carriers who contract with the PBM to determine if the transparency standards are being implemented as intended.
3	Open	Yes
We recommend that the Contracting Officer require the carrier contracts to include a true-up to ensure that each carrier receives the full value of all discounts, rebates, credits, or any other financial guarantees or adjustments included within the PBM's contracts with pharmacies. The true-ups should ensure that only the final costs paid to the pharmacies and/or drug suppliers (including any post-POS reconciliations or true-ups) are passed on to the FEHBP.

Recommendation Number

Recommendation Status

Significant Recommendation

Additional Details

Open

Yes

We recommend that the Contracting Officer direct its carriers to consider pooling their resources into a common PBM agreement, which could potentially not only lower costs to the program but also to its Federal members.

Open

Yes

We recommend that the Contracting Officer complete a data analysis of the claims pricing for all FEHBP carriers who contract with the PBM to determine if the transparency standards are being implemented as intended.

Open

Yes