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Connecticut Claimed Unallowable Federal Reimbursement for Medicaid Physician-Administered Drugs That Were Not Invoiced to Manufacturers for Rebates

Issued on  | Posted on  | Report number: A-07-18-06078

Connecticut did not always comply with Federal Medicaid requirements for invoicing manufacturers for rebates for physician-administered drugs. Connecticut did not invoice manufacturers for rebates associated with $1.1 million (Federal share) in physician-administered drugs. Of this amount, $1.07 million was for single-source drugs, and $46,210 was for top-20 multiple-source drugs. Further, Connecticut did not submit the utilization data necessary to secure rebates for all other physician-administered drug claims totaling $2.8 million (Federal share).

We recommended that Connecticut refund to the Federal Government $1.07 million (Federal share) for claims for single-source physician-administered drugs, and $46,210 for claims for top-20 multiple-source physician-administered drugs, and work with the Centers for Medicare & Medicaid Services to determine the unallowable portion of the $2.8 million (Federal share) for other claims for outpatient physician-administered drugs that were at issue. We also made procedural recommendations to Connecticut.

Connecticut concurred with our first two recommendations and, for our other recommendations, described corrective actions that it had taken or planned to take.

19-A-07-128.01 to CMS - Closed Implemented
Closed on 05/29/2024
We recommend that the Connecticut Department of Social Services refund to the Federal Government $1,065,387 (Federal share) for claims for single source physician-administered drugs that were ineligible for Federal reimbursement.

19-A-07-128.02 to CMS - Closed Implemented
Closed on 05/29/2024
We recommend that the Connecticut Department of Social Services refund to the Federal Government $46,210 (Federal share) for claims for top-20 multiple-source physician-administered drugs that were ineligible for Federal reimbursement.

19-A-07-128.03 to CMS - Open Unimplemented
Update expected on 04/08/2025
We recommend that the Connecticut Department of Social Services work with CMS to determine the unallowable portion of $2,380,355 (Federal share) for other claims for outpatient physician-administered drugs that were submitted without NDCs or with invalid NDCs and that may have been ineligible for Federal reimbursement and refund that amount.

19-A-07-128.04 to CMS - Open Unimplemented
Update expected on 10/03/2025
We recommend that the Connecticut Department of Social Services work with CMS to determine whether the remaining $387,761 (Federal share) of other physician-administered drug claims could have been invoiced to the manufacturers to receive rebates and, if so, upon receipt of the rebates, refund the Federal share of the manufacturers' rebates for those claims.

19-A-07-128.05 to CMS - Closed Acceptable Alternative
Update expected on
We recommend that the Connecticut Department of Social Services work with CMS to determine and refund the unallowable portion of Federal reimbursement for physician-administered drugs that were not invoiced for rebates after December 31, 2016.

19-A-07-128.06 to CMS - Closed Implemented
Closed on 11/13/2024
We recommend that the Connecticut Department of Social Services strengthen its internal controls to ensure that all physician-administered drugs eligible for rebates are invoiced.

View in Recommendation Tracker

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