It is CiiTA’s firm belief 340B stakeholders are generally well-intentioned. However, it is very common for errors to occur within Medicaid claims processing, and manufacturers must maintain a constant vigilance against such errors by continuously reviewing their data and following up on anomalies.
In one case, CiiTA identified an anomaly related to Medicaid claims submitted through the pharmacies associated with a covered entity during a routine data
assessment. The client requested that we initiate a good faith inquiry with the entity on their behalf. The entity participated in the inquiry, and with the help of its contract pharmacy administrator, we were jointly able to determine that the state had inadvertently submitted a large number of the entity’s 340B-identified claims for Medicaid rebates, thereby inadvertently triggering duplicate discounts. These duplicate discounts totaled more than $275,000 for the two years reviewed. The recoveries represented a return of more than 18:1 for the manufacturer on the cost of the engagement.
It is important to note that all parties acted in the very best of faith, and that the issue was only discovered through CiiTA’s ongoing review of our client’s Medicaid rebate data.