| 3 |
No |
$0 |
$12,484,472 |
|
|
We recommend that OPM's Contracting Officer require the PBM and Carrier to return $12,484,472 to the FEHBP for its portion of retail pharmacy pricing discounts not received from the PBM for CYs 2016 through 2021.
|
| 8 |
No |
$0 |
$1,397,520 |
|
|
We recommend that OPM's Contracting Officer require the PBM and Carrier to return the FEHBP's portion of the PBM's "non-specific drug discounts" going back to the start of the Carrier's transparent agreement with the PBM, specifically for the period of CYs 2012 through 2015. The PBM has already identified an additional $1,397,520 in drug inventory purchasing discounts for CY 2015 that should be returned to the FEHBP as overcharges.
|
| 4 |
No |
$0 |
$1,884,412 |
|
|
We recommend that OPM's Contracting Officer assess the PBM and Carrier $1,884,412 for LII on the questioned costs due back to the FEHBP for this finding, calculated through December 31, 2023. The LII should be adjusted to account for the date the questioned costs are returned to the program.
|
| 5 |
No |
$0 |
$0 |
|
|
We recommend that OPM's Contracting Officer require the Carrier to adopt new controls to ensure that the PBM charges no greater than the value of the PBM's negotiated discounts with each retail pharmacy in effect at the time of claim adjudication. True-ups to any retail pricing guarantees should be performed quarterly or annually in accordance with the Carrier's PBM agreement.
|
| 6 |
No |
$0 |
$5,911,973 |
|
|
We recommend that OPM's Contracting Officer require the PBM and Carrier to return $5,911,973 to the FEHBP for its portion of the PBM's non-specific drug inventory purchasing discounts that were not received for CYs 2016 through 2021.
|
| 7 |
No |
$0 |
$911,290 |
|
|
We recommend that OPM's Contracting Officer assess the PBM and Carrier $911,290 for LII on the questioned costs due back to the FEHBP for this finding, calculated through December 31, 2023. The LII should be adjusted to account for the date the questioned costs are returned to the program.
|
| 9 |
No |
$0 |
$0 |
|
|
We recommend that the Carrier adopt new controls to ensure that the PBM passes through all its drug inventory purchasing discounts associated with the Carrier and FEHBP in accordance with the PBM Transparency Standards for mail order and specialty drug actual acquisition costs.
|
| 10 |
No |
$0 |
$2,279,264 |
|
|
We recommend that Carrier collect $2,279,264 in claim transaction fees that were credited back to the PBM by retail pharmacies for the Carrier's CY 2016 through 2021 prescription drug benefits.
|
| 11 |
No |
$0 |
$289,501 |
|
|
We recommend that OPM's Contracting Officer assess the PBM and Carrier $289,501 for LII on the questioned costs due back to the FEHBP for this finding, calculated through December 31, 2023. The LII should be adjusted to account for the date the questioned costs are returned to the program.
|
| 12 |
No |
$0 |
$0 |
|
|
We recommend that the PBM adopt policies and procedures to ensure that the Carrier receives the value of all credits (i.e., claim transaction fees) that the PBM collects from retail pharmacies under pass-through transparent pricing.
|
| 13 |
No |
$0 |
$4,907,110 |
|
|
We recommend that the PBM return the remaining amount of $3,106,914 to the Carrier and the FEHBP for the underpayment of drug manufacturer rebates that were collected during CYs 2016 through 2021.
|
| 14 |
No |
$0 |
$374,636 |
|
|
We recommend that OPM's Contracting Officer assess the PBM and Carrier $374,636 for LII on the questioned costs due back to the FEHBP for this finding, calculated through December 31, 2023. The LII should be adjusted to account for the date the questioned costs are returned to the program.
|
| 15 |
No |
$0 |
$0 |
|
|
We recommend that the PBM adopt controls to ensure that all drug manufacturer rebates are properly allocated and passed through to the FEHBP.
|
