Review of Medicare Part D Prescription Drug Event Data for Schedule II Drugs at CVS Caremark Corporation

CVS Caremark Corporation did not have adequate controls to (1) prevent refills and unallowable partial fills of Schedule II drugs and (2) ensure the accuracy of certain fields in the Prescription Drug Event (PDE) records submitted for Schedule II drugs as required by Federal regulations. We found that 7 of 42 judgmentally selected PDE records represented unallowable partial fills (there were no refills), and 24 of 62 judgmentally selected PDE records contained inaccurate data when compared with the supporting documentation at the pharmacies. An additional two PDE records were missing pharmacy documentation, which prevented us from determining the accuracy of the data in the records.