CiiTA has a five-year partnership with a client to monitor and mitigate their 340B duplicate discount risk on an ongoing basis. During a recent evaluation of purchasing and Medicaid rebate data, we flagged a covered entity as having a high risk of potential duplicate discounts. CiiTA and the client jointly initiated a good faith inquiry with the entity. We requested that the entity review a very large set of claims that appeared to have been potentially subject to duplicate discounts.
The entity reviewed the data set and was able to verify that the claims in question had been processed as 340B by their institution. They independently reached out to the state Medicaid agency in question, who agreed to work with them to resolve the issue. They found that the state was incorrectly seeking rebates on the contract pharmacy dispensed claims filled with 340B inventory. This triggered inadvertent duplicate discounts between the 340B Program and Medicaid.
The identified duplicate discounts in this case totaled more than $16 million over two years. While this case is obviously an outlier in terms of scope of findings, it indicates just how critical it is for manufacturers to carefully and routinely monitor rebate and sales data.