CMS's Enhanced Controls Did Not Always Prevent Terminated Drug Utilization in Medicare Part D

The steps the Centers for Medicare & Medicaid Services (CMS) has taken to address terminated drug utilization in Medicare Part D were not entirely effective and, as a result, CMS continued to accept some prescription drug event (PDE) data for terminated drugs in calendar years (CYs) 2014 and 2015. Although CMS has made improvements to prevent terminated drug utilization in Part D, it accepted PDE data totaling $31.9 million in gross drug costs for 3,705 terminated drugs in CYs 2014 and 2015. CMS did not compare the information on termination dates in its quarterly Medicaid drug rebate files with the Food and Drug Administration's (FDA) file, did not investigate the discrepancies that existed between these two data sources, and did not update its system edits in a timely manner.