Oversight of the Prescriber Identifier Field in Prescription Drug Event Data for Schedule II Drugs

02-02-2011

Executive Summary

Our audit of Prescription Drug Event (PDE) records for Schedule II drugs found that approximately 228,000 PDE records with invalid prescriber identifiers (ID) accounted for approximately $20.6 million in gross drug costs in 2007. With limited guidance and edits in place for the prescriber ID field, CMS and the Medicare Part D sponsors have not identified these invalid prescriber IDs in the PDE records. Additionally, through our separate analysis of three Schedule II drugs that are most often reported in investigations, we were unable to identify the top prescribers for oxycodone, Ritalin, and methadone. Schedule II drugs have a high potential for abuse, have an accepted medical use with severe restrictions, and may cause severe psychological or physical dependence if abused.

To provide prescription drug benefits under Part D, CMS contracts with private entities called Part D sponsors that act as payers and insurers. Sponsors complete PDE records using information provided by the pharmacy responsible for filling the prescription. The prescriber ID field is filled by a number identifying the prescriber who is permitted to write prescriptions.

We recommended that CMS (1) issue specific guidance requiring sponsors to include a valid Drug Enforcement Administration number on both standard and nonstandard format PDE records involving Schedule II drugs and (2) implement an edit to reject PDE records for Schedule II drugs when the prescriber ID field contains an invalid prescriber ID number. CMS did not concur with our recommendations. In response, we modified our first recommendation, and we maintain our second recommendation.