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Report File
Date Issued
Submitting OIG
Office of Personnel Management OIG
Agencies Reviewed/Investigated
Office of Personnel Management
Report Number
2023-SAG-019
Report Type
Audit
Agency Wide
Yes
Number of Recommendations
11
Questioned Costs
$18,443,118
Funds for Better Use
$0
Report updated under NDAA 5274
Yes
External Entity
Compass Rose Health Plan

Open Recommendations

This report has 9 open recommendations.
Recommendation Number Significant Recommendation Recommended Questioned Costs Recommended Funds for Better Use Additional Details
1 No $0 $5,819,737

We recommend that OPM's Contracting Officer require the PBM to return $5,819,737 to the Carrier and the FEHBP for the portion of retail pharmacy discounts not passed through to the FEHBP during CYs 2017 through 2022.

2 No $0 $735,635

We recommend that OPM's Contracting Officer assess the PBM and Carrier $735,635 for LII on the questioned costs due back to the FEHBP for this finding, calculated through June 30, 2024. The LII should be adjusted to account for the date the questioned costs are returned to the program.

3 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 that was in effect at the time the claim was adjudicated. True ups to any retail pricing guarantees between the PBM and the Carrier should be performed quarterly or annually in accordance with the Carrier's PBM agreement.

5 No $0 $119,438

We recommend that OPM's Contracting Officer assess the PBM and Carrier $119,438 for LII on the questioned costs due back to the FEHBP for this finding, calculated through June 30, 2024. The LII should be adjusted to account for the date the questioned costs are returned to the program.

4 No $0 $925,895

We recommend that the Carrier collect $925,895 in claim transaction fees that were credited back to the PBM by retail pharmacies for the FEHBP's CY 2017 through 2022 prescription drug benefits and return this amount to the FEHBP.

6 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.

7 No $0 $190,134

We recommend that OPM's Contracting Officer require the PBM and Carrier to return $190,134 to the FEHBP for its portion of the PBM's non-specific drug inventory purchasing discounts that were not received for CYs 2017 through 2022.

8 No $0 $58,060

We recommend that OPM's Contracting Officer assess the PBM and Carrier $58,060 for LII on the questioned costs due back to the FEHBP for this finding, calculated through June 30, 2024. 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 the FEHBP in accordance with the PBM transparency standards for mail order and specialty drug actual acquisition costs.

Office of Personnel Management OIG

United States