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Pennsylvania Correctly Invoiced Rebates to Manufacturers for Most Physician-Administered Drugs Dispensed to Enrollees of Medicaid Managed-Care Organizations

Issued on  | Posted on  | Report number: A-03-24-00206

Why OIG Did This Audit

  • For a covered outpatient drug to be eligible for Federal reimbursement under the Medicaid program’s drug rebate requirements, manufacturers must pay rebates to the States for the drugs.
  • Prior OIG audits found that States did not always invoice and collect all rebates due for drugs administered to Medicaid managed-care organization (MCO) enrollees.
  • This audit, one of a series, determined whether Pennsylvania complied with Federal Medicaid requirements for invoicing manufacturers for rebates for physician-administered drugs dispensed to MCO enrollees.

What OIG Found

  • Pennsylvania generally complied with applicable Federal Medicaid requirements but did not invoice all rebate eligible physician-administered drugs dispensed to MCO enrollees.
  • Specifically, Pennsylvania did not invoice for rebates totaling $488,051 ($284,617 Federal share):

What OIG Recommends

We made three recommendations to Pennsylvania, including that Pennsylvania invoice for and collect from manufacturers rebates totaling $488,051 ($284,617 Federal share) for single-source and top-20 multiple-source physician-administered drugs and refund the Federal share of rebates collected. The full recommendations are in the report.

Pennsylvania agreed with all three recommendations.

26-A-03-009.01 to CMS - Open Unimplemented
Update expected on 05/04/2026
We recommend that the Pennsylvania Department of Human Services invoice for and collect from manufacturers rebates totaling $488,051 ($284,617 Federal share) for single-source and top-20 multiple-source physician-administered drugs and refund the Federal share of rebates collected.

26-A-03-009.02 to CMS - Open Unimplemented
Update expected on 05/04/2026
We recommend that the Pennsylvania Department of Human Services continue to review exclusion reports and invoice manufacturers for rebate-eligible drugs dispensed after our audit period.

26-A-03-009.03 to CMS - Open Unimplemented
Update expected on 05/04/2026
We recommend that the Pennsylvania Department of Human Services update its policies and procedures to require steps to regularly review exclusion reports for rebate eligible NDCs, and invoice for rebate those drugs identified as rebate eligible.

View in Recommendation Tracker

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