Montana Correctly Claimed Federal Reimbursement for Most Medicaid Physician-Administered Drugs

Although the Montana Department of Public Health and Human Services (State agency) generally complied with Federal Medicaid requirements for invoicing manufacturers for rebates for physician-administered drugs, it claimed unallowable Federal reimbursement for some of these drugs. The State agency did not invoice manufacturers for rebates associated with $24,000 ($16,000 Federal share) in physician-administered drugs. Of this amount, $19,000 ($13,000 Federal share) was for single-source drugs, and $5,000 ($3,000 Federal share) was for top-20 multiple-source drugs. Because the State agency's internal controls did not always ensure that it invoiced manufacturers to secure rebates, the State agency improperly claimed Federal reimbursement for these single-source drugs and top-20 multiple-source drugs.

Further, the State agency did not submit the utilization data necessary to secure rebates for all other physician-administered drugs. Although the State agency generally collected the drug utilization data necessary to invoice the manufacturers for rebates associated with these claims, providers submitted claims totaling $128,000 ($85,000 Federal share) that did not have national drug codes (NDCs). We were unable to determine whether the State agency was required to invoice for rebates for these other physician-administered drug claims that did not have NDCs in the utilization data. Furthermore, under the Medicaid drug rebate program, claims totaling $47,000 ($31,000 Federal share), which contained NDCs, could have been eligible for rebates.