Department of Health and Human Services 
OFFICE OF 
 
INSPECTOR GENERAL 
 
 
 
 
 
 
 
P D P G
AR  T    LANS  ENERALLY 
 
I D C
NCLUDE  RUGS  OMMONLY 
U D E :
SED BY  UAL  LIGIBLES   
2018 
(I C , S C ) 
NITIAL  APS   MALL  APS
 
Suzanne Murrin  
Deputy Inspector General 
For Evaluation and Inspections 
 
June 2018 
OEI-05-18-00240   
Report in Brief 
June 2018   
OEI-05-18-00240   
 
Why OIG Did This Review   Part D Plans Generally Include Drugs 
The Patient Protection and Affordable  Commonly Used by Dual Eligibles:  2018  
Care Act (ACA) requires OIG to conduct 
a study of the extent to which  Key Takeaway 
What OIG Found 
formularies used by Medicare Part D 
Overall, we found that the rate of Part D  Overall, we found that the rate of 
plans include drugs commonly used by  plan formularies inclusion of the  Part D plan formularies inclusion 
full-benefit dual-eligible individuals  of the drugs commonly used by 
197 drugs commonly used by dual 
(i.e., individuals who are eligible for  dual eligibles is high, with some 
eligibles is high, with some variation.  On 
both Medicare and full Medicaid  variation.  Because some 
average, Part D plan formularies include 
benefits).  These individuals generally  variation exists in formularies 
96 percent of the 197 commonly used 
inclusion and utilization 
get drug coverage through Medicare 
drugs.  In addition, 68 percent of the 
management of these drugs, 
Part D.  Pursuant to the ACA, OIG must 
commonly used drugs are included by all 
some dual eligibles may need to 
annually issue a report with 
Part D plan formularies.  These results are  make additional efforts to access 
recommendations as appropriate.  This 
largely unchanged from OIGs findings for  the drugs they take.  For instance, 
is the eighth report OIG has produced 
formularies reported in the mandated  they may chose to appeal 
to meet this mandate.  annual report from 2017, as well as our  prescription drug coverage 
decisions, switch prescription 
How OIG Did This Review  findings from 2011 through 2016. 
drugs, or switch Part D plans.  
For this report, we determined whether 
We also found that the percentage of  Because these scenarios require 
the 386 unique formularies used by the 
drugs to which plan formularies applied  additional effort by dual eligibles, 
3,476 Part D plans operating in 2018  utilization management tools increased  they may result in administrative 
cover the 200 drugs most commonly  slightly between 2017 and 2018.  On  barriers to accessing certain 
used by dual eligibles.  We also  average, formularies applied utilization  prescription drugs. 
determined the extent to which plan 
management tools to 29 percent of the 
formularies applied utilization 
unique drugs we reviewed in 2018, an increase of 1 percentage 
management tools to those commonly 
point from 2017. 
used drugs.  To create the list of the 
What OIG Concludes   
200 drugs most commonly used by dual 
Inclusion rates for the 197 drugs commonly used by dual 
eligibles, we used data from the 2013 
eligibles are largely unchanged compared with the inclusion 
Medicare Current Beneficiary Survey
rates listed in our previous reports.  Part D formularies include 
the most recent data available at the 
roughly the same high percentage of these commonly used 
time of our study.  Of the top 200 
drugs in 2018 as they did in 2017.   
drugs, 197 are eligible for Part D 
prescription drug coverage, 2 are  As mandated by the ACA, OIG will continue to monitor and 
excluded from coverage, and 1 is a Part  produce annual reports on the extent to which Part D plan 
D covered medical supply item.    formularies cover drugs that dual eligibles commonly use.  In 
addition, OIG will continue to monitor Part D plan formularies 
application of utilization management tools to these drugs.  OIG 
has no recommendations at this time. 
 
 
 
   
TABLE OF CONTENTS 
 
Objectives ....................................................................................................1 
Background ..................................................................................................1 
Methodology ................................................................................................6 
Findings......................................................................................................12 
Part D Plan Formularies Include Between 85 and 100 Percent of 
the Drugs Commonly Used by Dual Eligibles ...............................12 
Sixty-Eight Percent of the Drugs Commonly Used by Dual 
Eligibles Are Included in All Part D Plan Formularies ..................14 
The Percentage of Commonly Used Drugs To Which Plan 
Formularies Applied Utilization Management Tools Increased 
Slightly Between 2017 and 2018 ...................................................17 
Conclusion .................................................................................................20 
Appendixes ................................................................................................21 
A:  Section 3313 of the Patient Protection and Affordable Care 
Act of 2010 ....................................................................................21 
B:  List of Mandated OIG Reports Examining Dual Eligible Access 
to Drugs Under Part D ...................................................................22 
C:  Commonly Used Drugs and Rates of Inclusion by 
Formularies ....................................................................................23 
D:  Two Drugs Commonly Used by Dual Eligibles and Not 
Covered Under Part D ....................................................................29 
E:  Formulary Inclusion of Stand-Alone Prescription Drug Plans 
and Medicare Advantage Prescription Drug Plans, by Region ......30 
Acknowledgments......................................................................................32 
 
   
   
   
OBJECTIVES 
1.  To determine the extent to which Part D plan formularies cover the 
drugs commonly used by dual eligibles. 
2.  To determine the extent to which Part D plan formularies applied 
utilization management tools to the drugs commonly used by dual 
eligibles. 
BACKGROUND  
Pursuant to the Medicare Prescription Drug, Improvement, and 
Modernization Act of 2003 (MMA), comprehensive prescription drug 
coverage under Medicare Part D is available to all Medicare beneficiaries 
through prescription drug plans (PDPs) and Medicare Advantage 
prescription drug plans (MA-PDs), hereinafter referred to collectively as 
Part D plans.1  
For beneficiaries who are eligible for both Medicare and Medicaid 
(hereinafter referred to as dual eligibles), Medicare covers Part D plan 
premiums, deductibles, and other cost-sharing up to a determined 
premium benchmark that varies by region.  If dual eligibles enroll in 
Part D plans with premiums higher than the regional benchmark, they are 
responsible for paying the premium amounts above that benchmark. 
To control costs and ensure the safe use of drugs, Part D plans are allowed 
to establish formularies from which they may omit drugs from prescription 
coverage and are allowed to control drug utilization through utilization 
management tools.2  These tools include prior authorization, quantity 
limits, and step therapy.3   
The Centers for Medicare & Medicaid Services (CMS) annually reviews 
Part D plan formularies to ensure that they include a range of drugs in a 
broad distribution of therapeutic categories or classes.  CMS also assesses 
the utilization management tools present in each formulary. 
   
                                                 
1 MMA, P.L. No. 108-173  101, Social Security Act,  1860D-1(a). 
2 A formulary is a list of drugs covered by a Part D plan.  Part D plans can exclude drugs 
from their formularies and can control utilization for formulary-included drugs within 
certain parameters.  Social Security Act  1860D-4(b) and (c). 
3 Prior authorizationoften required for very expensive drugsrequires that physicians 
obtain approval from Part D plans to prescribe a specific drug.  Quantity limits are 
intended to ensure that beneficiaries receive the proper dose and recommended duration 
of drug therapy.  Step therapy is the practice of beginning drug therapy for a medical 
condition with the drug therapy that is the most cost-effective or safest and progressing if 
necessary to more costly or risky drug therapy. 
Part D Plans Generally Include Drugs Commonly Used by Dual Eligibles:  2018 (OEI-05-18-00240)  1 
     
   
The Medicare Prescription Drug Benefit 
Beginning in 2006, the MMA made comprehensive prescription drug 
coverage under Medicare Part D available to all Medicare beneficiaries.4  
Medicare beneficiaries generally have the option to enroll in a PDP and 
receive all other Medicare benefits on a fee-for-service basis, or to enroll 
in an MA-PD and receive all of their Medicare benefits, including 
prescription drug coverage, through managed care.5  As of January 2018, 
approximately 43.8 million of the 59.2 million Medicare beneficiaries 
were enrolled in a Part D plan. 
Part D plans are administered by private companiesknown as plan 
sponsorsthat contract with CMS to offer prescription drug coverage in 
one or more PDP or MA-PD regions.  CMS has designated 34 PDP 
regions and 26 MA-PD regions.  In 2018, plan sponsors offer 
3,476 unique Part D plans, with many plan sponsors offering multiple 
Part D plans.  
Dual Eligibles Under Medicare Part D  
Approximately 10.9 million Medicare beneficiaries are dual eligibles.  For 
about 8 million dual eligibles, referred to as full-benefit dual eligibles, 
Medicaid provides full Medicaid benefits, including Medicaid-covered 
services, and may also assist beneficiaries with premiums and cost-sharing 
for Medicare fee-for-service or Medicare managed care.6  For other dual 
eligibles, Medicaid does not provide Medicaid-covered services, but 
provides assistance with beneficiaries Medicare premiums or 
cost-sharing, depending on their level of income and assets. 
Dual eligibles are a particularly vulnerable population.  Overall, most dual 
eligibles have very low incomes:  86 percent have annual incomes below 
150 percent of the Federal poverty level, compared with 22 percent of all 
other Medicare beneficiaries.  Additionally, dual eligibles are in worse 
health than the average Medicare beneficiaryhalf are in fair or poor 
health, more than twice the rate of others in Medicare.7  Because of their 
self-reported health needs, dual eligibles may use more prescription drugs 
and health care services in general than other Medicare beneficiaries. 
Until December 31, 2005, dual eligibles received outpatient prescription 
drug benefits through Medicaid.  In January 2006, Medicare began 
                                                 
4 MMA, P.L. No. 108-173  101, Social Security Act,  1860D-1(a). 
5 CMS, PDBM, ch. 1,  10.1. 
6 Kaiser Family Foundation, Medicares Role for Dual Eligible Beneficiaries.  Accessed 
at http://www.kff.org/medicare/upload/8138-02.pdf on April 13, 2017. 
7 Ibid. 
Part D Plans Generally Include Drugs Commonly Used by Dual Eligibles:  2018 (OEI-05-18-00240)  2 
     
   
covering outpatient prescription drugs for dual eligibles through Part D 
plans.8 
Medicare covers Part D plan premiums for dual eligibles up to a set 
benchmark.  The benchmark is a statutorily defined amount that is based 
on the average premium amounts for Part D plans for each region.9, 10  If 
dual eligibles enroll in Part D plans with premiums higher than the 
regional benchmark, they are responsible for paying the premium amounts 
above that benchmark.11 
Dual eligibles assignment to Part D plans.  When individuals become 
eligible for both Medicare and Medicaid, CMS randomly assigns those 
individuals to PDPs unless they have elected a specific Part D plan or have 
opted out of Part D prescription drug coverage.12  The PDPs to which 
CMS assigns dual eligibles must meet certain requirements, such as 
having a premium at or below the regional benchmark amount and 
offering basic prescription drug coverage (or equivalent).13  Basic 
prescription drug coverage is defined in terms of benefit structure (initial 
coverage, coverage gap, and catastrophic coverage) and costs (initial 
deductible and coinsurance). 
Some dual eligibles may be randomly assigned to PDPs that do not cover 
the specific drugs they use.  However, unlike the general Medicare 
population, dual eligibles can switch Part D plans at any time to find plans 
that cover the prescription drugs they require.14  When dual eligibles 
change plans, their prescription drug coverage under the new Part D plan 
becomes effective at the beginning of the following month. 
CMS annually reassigns some dual eligibles to new PDPs if their current 
PDPs will have premiums above the regional benchmark premium for the 
                                                 
8 MMA, P.L. No. 108-173  101, Social Security Act,  1860D-1(a). 
9 Social Security Act,  1860D-14(b); 42 CFR  423.780(b)(2)(i) 
10 Dual eligibles residing in territories are not eligible to receive cost-sharing assistance 
from Medicare.  With this being the case, there are no benchmarks for Part D plans 
offered in the territories.  Social Security Act,  1860D-14(a)(3)(F). 
11 The ACA established a de minimis premium policy, whereby a Part D plan may elect 
to charge dual eligibles the benchmark premium amount if the Part D plans basic 
premium exceeds the regional benchmark by a de minimis amount.  Patient Protection 
and Affordable Care Act (ACA), P.L. No. 111-148  3303, Social Security Act, 
 1860D-14(a)(5).  For 2018, CMS set the de minimis amount at $2 above the regional 
benchmark. 
12 CMS, PDBM, ch. 3,  40.1.4. 
13 Ibid. 
14 Ibid.,  30.3.2.  In general, Medicare beneficiaries can switch Part D plans only once a 
year during a defined enrollment period. 
Part D Plans Generally Include Drugs Commonly Used by Dual Eligibles:  2018 (OEI-05-18-00240)  3 
     
   
following year. 15  For dual eligibles who were randomly assigned to their 
current PDPs, CMS chooses new PDPs that will have premiums at or 
below the regional benchmark premium.16  For dual eligibles who elected 
their current Part D plans, CMS notifies them that their plans will have 
premiums above the regional benchmark premium.  For 2018, CMS 
reported reassigning approximately 351,000 Medicare beneficiaries, 
including but not exclusively dual eligibles, because of premium 
increases. 
Part D Prescription Drug Coverage 
Under Part D, plans can establish formularies from which they may 
exclude drugs and control drug utilization within certain parameters.  
These parameters are intended to balance Medicare beneficiaries needs 
for adequate prescription drug coverage with Part D plan sponsors needs 
to contain costs.  Generally, a formulary must include at least two drugs in 
each therapeutic category or class.17, 18  In addition, Part D plans must 
include Part D-covered drugs in certain categories and classes.19  
Part D plans may also control drug utilization by applying utilization 
management tools.  These tools include requiring prior authorization to 
obtain drugs that are on plan formularies, establishing quantity limits, and 
requiring step therapy.  Utilization management tools can help Part D 
plans and the Part D program limit the cost of prescription drug coverage 
by placing restrictions on the use of certain drugs. 
In addition to these drug coverage decisions that Part D plans make 
regarding individual formularies, certain categories of drugs are excluded 
from Medicare Part D prescription drug coverage as mandated by the 
MMA.20  For example, prescription vitamins, prescription mineral 
products, and nonprescription drugs are excluded from Part D prescription 
drug coverage.21    
Until 2013, barbiturates and benzodiazepines were excluded from Part D 
prescription drug coverage.  However, the ACA reversed this exclusion, 
                                                 
15 Ibid.,  40.1.5. 
16 CMS, PDBM,  40.1.5. 
17 Ibid., ch. 6,  30.2.1. 
18 Therapeutic categories or classes classify drugs according to their most common 
intended uses.  For example, cardiovascular agents compose a therapeutic class intended 
to affect the rate or intensity of cardiac contraction, blood vessel diameter, or blood 
volume. 
19 Social Security Act,  1860D-4(b)(3)(G). 
20 MMA, P.L. No. 108-173  101, Social Security Act,  1860D-2(e). 
21 Social Security Act  1860D-2(e)(2), 1927(d)(2). 
Part D Plans Generally Include Drugs Commonly Used by Dual Eligibles:  2018 (OEI-05-18-00240)  4 
     
   
removing these two drug types from the list of drug classes ineligible for 
such coverage.22, 23 
CMS Efforts To Ensure Prescription Drug Coverage 
Formulary Review.  CMS annually reviews Part D plan formularies to 
ensure that they include a range of drugs in a broad distribution of 
therapeutic categories or classes, as well as all drugs in specified 
therapeutic categories or classes.24  During this review, CMS analyzes 
formularies coverage of the drug classes most commonly prescribed for 
the Medicare population.  CMS intends for Part D plans to cover the most 
widely used medications, or therapeutically alternative medications (i.e., 
drugs from the same therapeutic category or class), for the most common 
conditions.  CMS uses Part D prescription drug data to identify the most 
commonly prescribed classes of drugs.25  
CMS also assesses each formularys utilization management tools to 
ensure consistency with current industry standards and with standards that 
are widely used with drugs for the elderly and people with 
disabilities.26, 27, 28 
Exceptions and appeals process.  CMS has implemented an exceptions 
and appeals process whereby beneficiaries can request coverage of 
nonformulary drugs or an exception to a utilization management tool that 
applies to a formulary drug.  When a Part D plan receives a prescribers 
statement supporting an exception request, the plan must notify the 
beneficiary of its determination within 72 hours or, for expedited requests, 
within 24 hours.29  If the beneficiarys plan makes an adverse 
determination, the beneficiary has the right to appeal.30  If the plan 
continues to deny the beneficiarys request, the beneficiary has additional 
appeal rights and may continue to appeal until those rights are exhausted.  
Alternatively, the beneficiary can work with his or her prescriber to 
                                                 
22 ACA, P.L. No. 111-148  2502, Social Security Act,  1927(d). 
23 CMS, Transition to Part D Coverage of Benzodiazepines and Barbiturates Beginning 
in 2013.  Accessed at http://www.cms.gov/Medicare/Prescription-Drug-
Coverage/PrescriptionDrugCovContra/Downloads/BenzoandBarbituratesin2013.pdf on 
April 13, 2017. 
24 CMS, PDBM, ch. 6,  30.2.7. 
25 Ibid. 
26 Ibid.,  30.2.2. 
27 Ibid.,  30.2.7. 
28 CMS looks to appropriate guidelines from expert organizations such as the National 
Committee for Quality Assurance, the Academy of Managed Care Pharmacy, and the 
National Association of Insurance Commissioners. 
29 CMS, PDBM, ch. 18,  30.1 and 30.2. 
30 Ibid.,  60.1. 
Part D Plans Generally Include Drugs Commonly Used by Dual Eligibles:  2018 (OEI-05-18-00240)  5 
     
   
determine whether there is an appropriate therapeutically equivalent 
alternative drug on the plans formulary. 
Transitioning new enrollees to Part D.  CMS requires that Part D plans 
establish a transition process for new enrollees (including dual eligibles) 
who are transitioning to their respective Part D plans either from different 
Part D plans or from other prescription drug coverage.  During Medicare 
beneficiaries first 90 days under a new Part D plan, the new plan must 
provide one temporary fill of a prescription when beneficiaries request 
either a drug that is not in the plans formulary or a drug that requires prior 
authorization or step therapy under the formularys utilization 
management tools.31  The temporary fill accommodates beneficiaries 
immediate drug needs the first time they attempt to fill a prescription.  The 
transition period also allows beneficiaries time to work with their 
prescribing physicians to obtain prescriptions for therapeutically 
alternative drugs or to request formulary exceptions from Part D plans. 
Related OIG Work 
In 2006, OIG published a report assessing the extent to which PDP 
formularies included drugs commonly used by dual eligibles under 
Medicaid.  The study found that PDP formularies included between 76 and 
100 percent of the 178 drugs commonly used by dual eligibles under 
Medicaid prior to the implementation of Part D.  Approximately half of 
the 178 commonly used drugs were covered by all formularies.32  
In 2011, OIG issued the first annual mandated report examining dual 
eligibles access to drugs under Medicare Part D.  See Appendix A for 
statutory mandate.  We have released an annual mandated report each year 
since then.  See Appendix B for list of reports.  The current report is the 
eighth report released. 
METHODOLOGY 
Scope 
As mandated in the ACA, this study assessed the extent to which drugs 
commonly used by dual eligibles are included by Part D plan formularies.  
To make this assessment, we evaluated formularies for Part D plans 
operating in 2018.  As part of our assessment, we included dual eligibles 
enrollment data from January 2018, the most recent enrollment data 
                                                 
31 CMS, PDBM, ch. 6,  30.4.4. 
32 OIG, Dual Eligibles Transition:  Part D Formularies Inclusion of Commonly Used 
Drugs, OEI-05-06-00090, January 2006. 
Part D Plans Generally Include Drugs Commonly Used by Dual Eligibles:  2018 (OEI-05-18-00240)  6 
     
   
available from CMS at the time of our study.  We also compared the 
results of our 2018 study with those of our 2017 study. 33 
The ACA did not define which drugs commonly used by dual eligibles we 
should review.  We defined drugs commonly used by dual eligibles as the 
200 drugs with the highest utilization by dual eligibles as reported in the 
Medicare Current Beneficiary Survey (MCBS)i.e., the 2013 MCBS.  
We used the MCBS because it contains drugs that dual eligibles received 
through multiple sources (e.g., Part D, Medicaid, and the Department of 
Veterans Affairs) and, as such, it provides a comprehensive picture of drug 
utilization.  Of the 200 highest utilization drugs that we identified using 
the MCBS, 197 are eligible for coverage under Part D.  In this report, we 
refer to these 197 Part D-eligible high utilization drugs as commonly 
used drugs. 
For each study, OIG went beyond the ACAs mandate by reviewing drug 
coverage for all dual eligibles under Medicare Part D, rather than only for 
full-benefit dual eligibles.  With the data available for this study, we could 
not confidently identify and segregate full-benefit dual eligiblesand thus 
the drugs they usedfrom the total population of dual eligibles. 
We also went beyond the ACAs mandate in the 2013 to 2017 reports by 
examining the utilization management tools that Part D plan formularies 
apply to the drugs commonly used by dual eligibles.  These tools may 
affect dual eligibles access even in cases where formularies include the 
commonly used drugs.  Analyzing the extent to which Part D plan 
formularies apply these tools to drugs commonly used by dual eligibles 
allows us to provide a comprehensive picture of Part D plan formularies 
coverage of, and dual eligibles access to, those drugs. 
Data Sources 
MCBS.  We used the 2013 MCBS Cost and Use data to create a list of the 
200 drugs with the highest utilization by dual eligibles.  The MCBS Cost 
and Use data contain information on hospitals, physicians, and 
prescription drug costs and utilization.  The 2013 MCBS Cost and Use 
data were the most recent data available at the time of our study.  
Historically, the list of the 200 drugs with the highest utilization by dual 
eligibles has remained largely unchanged between one year and the next.  
The list for 2018 overlapped by 91 percent with the list for 2017, which in 
turn overlapped by 91 percent with the list for 2015.34 
                                                 
33 OIG, Part D Plans Generally Include Drugs Commonly Used by Dual Eligibles:  2016, 
OEI-05-16-00090, June 2016. 
34 In 2018, we used the 2013 data and in 2017 and 2016, we used the 2012 data.  In 2015, 
we used 2011 data. 
Part D Plans Generally Include Drugs Commonly Used by Dual Eligibles:  2018 (OEI-05-18-00240)  7 
     
   
The MCBS is a continuous, multipurpose survey that CMS conducts of 
a representative national sample of the Medicare population, including 
dual eligibles.  Sampled Medicare beneficiaries were interviewed three 
times per year and asked what drugs they were taking and whether they 
had started taking any new drugs since the previous interview.  The MCBS 
also includes Part D prescription drug events for surveyed Medicare 
beneficiaries.  In 2013, the MCBS surveyed 11,049 Medicare 
beneficiaries, of whom 2,456 were dual eligibles who had used 
prescription drugs during the year (out of 2,718 dual-eligible survey 
respondents). 
First DataBank National Drug Data File.  We used the March 2013 First 
DataBank National Drug Data File to identify the drug product 
information for the 200 drugs with the highest utilization by dual 
eligibles.35  The National Drug Data File is a database that contains 
informationsuch as drug name, therapeutic category or class, and the 
unique combination of active ingredientsfor each drug as defined by a 
National Drug Code (NDC).36 
Part D plan data.  In February 2018, we collected from CMS the 
formulary data and the plan data for Part D plans operating in 2018.  The 
formulary data includes Part D plans formularies and utilization 
management tools for plans operating in 2018.  In 2018, there are 386 
unique formularies offered by 3,476 Part D plans.  The plan data provides 
information such as the State in which a Part D plan is offered, whether 
the Part D plan is a PDP or an MA-PD, and whether the Part D plan 
premium is below the regional benchmark.   
We also collected 2018 enrollment data for Part D plans.  These data 
provide the number of dual eligibles enrolled in each Part D plan as of 
January 2018. 
Determining the Most Commonly Used Drugs 
To determine the drugs most commonly used by dual eligibles, we took 
the following steps: 
1.  We created a list of all drugs reported by dual eligibles surveyed in 
the 2013 MCBS.  We excluded respondents from territories 
because they are not eligible to receive cost-sharing assistance 
                                                 
35 The Mach 2013 First Databank National Drug Data File would have been in effect 
when the MCBS survey was being conducted 
36 An NDC is a three-part universal identifier that specifies the drug manufacturers 
name, the drug form and strength, and the package size. 
Part D Plans Generally Include Drugs Commonly Used by Dual Eligibles:  2018 (OEI-05-18-00240)  8 
     
   
under Part D.  The MCBS listed 188,685 drug events for 
2,456 dual eligibles who did not reside in territories.37  
2.  We collapsed this list to a list of drugs based on their active 
ingredients, using the Ingredient List Identifier located in First 
DataBanks National Drug Data File.  For example, 
a multiple-source drug such as fluoxetine hydrochloride (the active 
ingredient for the brand-name drug Prozac) has only one entry on 
our list, covering all strengths of both the brand-name drug Prozac 
and the available generic versions of fluoxetine hydrochloride.  
From this point forward, unless otherwise stated, we will use the 
term drug to refer to any drug in the same Ingredient List 
Identifier category, and the term unique drug to refer to an NDC 
corresponding to a drug, as a given drug can have multiple NDCs.  
This process left 188,685 drug events associated with 871 drugs. 
3.  We ranked the 871 drugs by frequency of utilization, weighting the 
drug-event information from MCBS by sample weight. 
4.  We selected the 200 drugs with the highest utilization by dual 
eligibles.  For a full list of the top 200 drugs, see Appendix C. 
5.  We removed all drugs not covered under Part D.  Of the 200 drugs 
with the highest utilization, 197 are eligible under Part D.  One fell 
into a drug category excluded under Part D, and one is no longer 
prescribed in the form taken by beneficiaries surveyed in the 
2013 MCBS.  One additional drug is eligible for Part D 
prescription drug coverage.  However, we did not include it in our 
analysis because the drug represents a medical supply item that is 
covered under Part D.  For details on the two drugs excluded under 
Part D, see Appendix D. 
Formulary Analysis 
We analyzed the 386 unique Part D plan formularies to determine their 
rates of inclusion of the 197 drugs commonly used by dual eligibles.  We 
counted a drug as included in a Part D plans formulary if the formulary 
included the active ingredient.  When a drug included multiple ingredients 
that could be dispensed separately and combined by the patient to the 
same effect as the combined drug, we treated the drug as included if the 
ingredients were included in the formulary either separately or in 
combination. 
                                                 
37 For the purposes of this report, a drug event is an MCBS survey response indicating 
that the responding beneficiary took a specific drug at least once in 2013.  For example, 
1 MCBS survey respondent reported taking rosuvastatin calcium (Crestor) 12 times in 
2012.  We counted this beneficiary/drug combination as 12 drug events. 
Part D Plans Generally Include Drugs Commonly Used by Dual Eligibles:  2018 (OEI-05-18-00240)  9 
     
   
Low rates of inclusion by formularies.  We determined which of the 
197 commonly used drugs had low rates of inclusion by formularies by 
counting how many of the 386 formularies covered each drug.  We 
considered a drug to have a low rate of inclusion if it was included by 
75 percent or less of formularies.  For such drugs, we counted the number 
of drugs (if any) that each formulary covered in the same therapeutic 
category or class.   
We conducted this analysis to ensure that dual eligibles have access to 
therapeutically similar drugs.  We also conducted additional research to 
identify potential reasons why some of the 197 commonly used drugs 
were included by 75 percent or less of formularies. 
Utilization management tools.  We determined the extent to which Part D 
plans apply utilization management tools to the 197 drugs that we 
reviewed.  The tools that we reviewed are prior authorization, quantity 
limits, and step therapy. 
To determine the extent to which Part D plan formularies applied 
utilization management tools to the 197 commonly used drugs, we 
conducted an analysis of the NDCs that correspond to the commonly used 
drugs.  Part D plan formularies do not apply utilization management tools 
at the active ingredient level.  Rather, Part D plan formularies apply 
utilization management tools at a more specific level that identifies 
whether a drug is brand-name or generic and its dosage form, strength, and 
route of administration, irrespective of package size.  To conduct this 
analysis, we determined the NDCs (unique drugs) associated with each of 
the 197 commonly used drugs that are on each Part D formulary.  We then 
calculated the percentage of unique drugs to which each Part D plan 
formulary applies utilization management tools. 
Enrollment Analysis 
We weighted the formulary analysis by dual-eligible enrollment and 
weighted the analysis of utilization management tools by both 
dual-eligible enrollment and Medicare enrollment.  To do this, we applied 
enrollment data from January 2018 to Part D plans available in 2018. 
Data Limitations   
We did not assess individual dual eligibles prescription drug use or 
whether individual dual eligibles are enrolled in Part D plans that include 
the specific drugs that each individual uses.  Because we relied on 
a sample of dual eligibles responding to the MCBS to develop our list of 
commonly used drugs, a particular dual eligible might not use any of the 
drugs on our list.  However, the drugs most commonly used by 
dual-eligible MCBS survey participants in 2013 account for 88 percent of 
Part D Plans Generally Include Drugs Commonly Used by Dual Eligibles:  2018 (OEI-05-18-00240)  10 
     
   
all prescriptions dispensed to the dual-eligible respondents in the 
2013 MCBS. 
Standards 
This study was conducted in accordance with the Quality Standards for 
Inspection and Evaluation issued by the Council of the Inspectors General 
on Integrity and Efficiency. 
   
Part D Plans Generally Include Drugs Commonly Used by Dual Eligibles:  2018 (OEI-05-18-00240)  11 
     
   
FINDINGS 
Part D Plan Formularies Include Between 85 and 
100 Percent of the Drugs Commonly Used by Dual 
Eligibles 
On average, Part D plan formularies include 96 percent of the drugs 
commonly used by dual eligibles.  Of the 386 unique formularies used by 
Part D plans in 2018, 12 formularies include 100 percent of the commonly 
used drugs.  At the other end of the inclusion range, two formularies 
include 85 percent of the commonly used drugs.  Exhibit 1 provides 
a breakdown of the formularies inclusion rates for the drugs most 
commonly used by dual eligibles.  CMS generally requires Part D plan 
formularies to include at least two drugsrather than all drugsin each 
therapeutic category or class.  Therefore, Part D plan formularies may still 
meet CMSs formulary requirements even if they do not include all of the 
drugs we identified as commonly used by dual eligibles.
Exhibit 1:  Nearly two-thirds of Part D plan formularies cover at least 
96 percent of the drugs commonly used by dual eligibles. 
Source:  OIG analysis of formulary inclusion of drugs commonly used by dual eligibles, 2018. 
Part D plan formularies rate of inclusion of the drugs commonly used by 
dual eligibles in 2018 is similar to that of 2017.  The average rate of 
inclusion decreased slightly between 2017 and 2018, from 97 percent to 
96 percent.  The range of inclusion rates in 2017 and 2018 differ slightly 
with 85 to 100 percent of drugs commonly used by dual eligibles in 2018 
compared with 88 to 100 percent in 2017. 
Part D Plans Generally Include Drugs Commonly Used by Dual Eligibles:  2018 (OEI-05-18-00240)  12 
     
   
Nationally, PDP and MA-PD formularies have similar rates of inclusion of 
the drugs commonly used by dual eligibles, averaging 95 percent and 
97 percent, respectively.  For PDP formularies, the rates of inclusion 
ranged from 85 to 99 percent.  For MA-PD formularies, the rates of 
inclusion ranged from 85 to 100 percent.  Seven formularies2 percent of 
the 386 unique formularies used by Part D plans in 2018are offered by 
both PDPs and MA-PDs. 
Regionally, all dual eligibles have the choice of a Part D plan that includes 
at least 98 percent of the commonly used drugs.  Every PDP region has 
a plan that includes at least 99 percent of the commonly used drugs, and 
every MA-PD region has a plan that includes at least 98 percent of these 
drugs.  Appendix E provides a breakdown of formularies rates of 
inclusion of the drugs by PDP and MA-PD region. 
On average, formularies for Part D plans with premiums below 
the regional benchmark include 96 percent of the drugs 
commonly used by dual eligibles 
The percentage of drugs included by Part D plans with premiums below 
the regional benchmark is important because dual eligibles are 
automatically enrolled in, or annually reassigned to, such plans.  For drugs 
commonly used by dual eligibles, formularies for such plans have rates of 
inclusion that range from 85 percent to 100 percent.  Approximately 
86 percent of dual eligibles are enrolled in Part D plans with premiums 
below the regional benchmark. 
Most dual eligibles are enrolled in Part D plans that include at 
least 90 percent of the drugs commonly used by dual eligibles 
Of the approximately 10.8 million dual eligibles enrolled in Part D plans, 
approximately 93 percent are enrolled in Part D plans that use formularies 
that include at least 90 percent of the commonly used drugs.  Seven 
percent of dual eligibles are enrolled in Part D plans that use formularies 
that include less than 90 percent of these drugs.  Exhibit 2 provides 
a breakdown of dual eligibles enrollment in Part D plans by the rates at 
which the plans formularies include the commonly used drugs. 
   
Part D Plans Generally Include Drugs Commonly Used by Dual Eligibles:  2018 (OEI-05-18-00240)  13 
     
   
Exhibit 2:  Enrollment of Dual Eligibles in Part D Plans, by Formularies 
Inclusion of Commonly Used Drugs 
Part D Plans With Formularies That  Number of Dual  Percentage of Dual 
Include:  Eligibles Enrolled  Eligibles Enrolled 
100% of commonly used drugs            222,880   2% 
95% to 99% of commonly used drugs           3,631,810   34% 
90% to 94% of commonly used drugs  6,133,779   57% 
85% to 89% of commonly used drugs  766,106  7% 
     Total               10.754,575   100% 
Source:  OIG analysis of formulary inclusion of drugs commonly used by dual eligibles and dual eligibles 
enrollment, 2018. 
The percentage of dual eligibles enrolled in Part D plans that include at 
least 90 percent of the drugs commonly used by dual eligibles decreased 
from 96 percent in 2017 to 93 percent in 2018. 
Sixty-Eight Percent of the Drugs Commonly Used by 
Dual Eligibles Are Included in All Part D Plan 
Formularies 
Because most of the commonly used drugs are included in a large 
percentage of formularies, dual eligibles can be confident that regardless 
of the Part D plan in which they are enrolled, the plans formulary will 
include many of these drugs.  By drug, inclusion in formularies ranges 
from 43 percent to 100 percent.  At one end of the range, there is a drug 
that is included in 43 percent of Part D plan formularies, and at the other 
end, 134 drugs are included in all plan formularies.  The average rate of 
inclusion in formularies is 96 percent.  Exhibit 3 shows the rates at which 
formularies include the 197 drugs.  Appendix C lists the 197 drugs and the 
rates at which formularies include them. 
Exhibit 3:  Formularies Rates of Inclusion of Commonly Used Drugs 
Percentage of the 197 Commonly 
Percentage of the 386 Formularies  Used Drugs Included in 
Formularies 
68% 
100% 
(134 drugs) 
22% 
85% to 99% 
(44 drugs) 
4% 
76% to 84% 
(7 drugs) 
6% 
43% to 75% 
(12 drugs) 
100% 
    Total 
(197 drugs) 
Source:  OIG analysis of formulary inclusion of drugs commonly used by dual eligibles, 2018. 
The rates at which formularies include the drugs commonly used by dual 
eligibles in 2018 are similar to those in 2017.  The percentage of 
Part D Plans Generally Include Drugs Commonly Used by Dual Eligibles:  2018 (OEI-05-18-00240)  14 
     
   
commonly used drugs included in all formularies decreased slightly 
between 2017 and 2018, from 70 percent to 68 percent. 
Part D plan formularies include certain drugs less frequently 
than others 
Of the commonly used drugs, 6 percent (12 drugs) are included by 
75 percent or less of Part D plan formularies.  Exhibit 4 provides the 
percentage of formularies covering each of these 12 drugs. 
The drugs that make up this group include both brand-name and generic 
drugs and are used to treat a variety of primary indications.  Six of the 
12 drugs are brand-name drugs, which are typically more costly than 
generic drugs.  As for the primary indications, 4 of the 12 drugs are used 
for diabetes therapy, 2 are muscle relaxants, 2 are used for gastrointestinal 
conditions, and the remaining drugs treat a variety of conditions. 
Exhibit 4:  Drugs Included by 75 Percent or Less of Part D Plan Formularies 
Rate of 
Generic Name of Drug  Primary Indication(s)  Inclusion by 
Formularies 
Solifenacin succinate   Overactive bladder, incontinence  74% 
Hydroxyzine Pamoate  Anxiety, Allergy Treatment  73% 
Insulin aspart  72% 
Diabetes 
Nebivolo Hcl  Hypertension  71% 
Tiotropium Bromide  Chronic Obstructive Pulmonary Disease  70% 
Esomeprazole magnesium  Dyspepsia, peptic ulcer disease, gastroesophageal reflux  64% 
disease, Zollinger-Ellison syndrome 
Methocarbamol  59% 
Musculoskeletal pain 
Insulin lispro  53% 
Diabetes 
Dexlansoprazole  52% 
Gastroesophageal reflux disease 
Glyburide  48% 
Diabetes 
Carisoprodol  Musculoskeletal pain  45% 
Glyburide/Metformin Hcl  Diabetes   43% 
Source:  OIG analysis of formularies inclusion of drugs commonly used by dual eligibles, 2018. 
The drugs in the shaded rows also had low rates of inclusion by formularies in 2017. 
 
Although Part D formularies frequently omit these 12 drugs, they all cover 
other drugs in the same respective therapeutic classes.  For each of these 
12 drugs, 100 percent of formularies cover at least 1 drug in the same 
therapeutic class that is also on the list of 197 drugs commonly used by 
dual eligibles. 
The number of drugs included by 75 percent or less of formularies 
increased from 10 in 2017 to 12 in 2018.  There are eight drugs with low 
inclusion rates in 2018 that were also on the list of commonly used drugs 
with low inclusion rates in our 2017 report; we note these eight drugs 
Part D Plans Generally Include Drugs Commonly Used by Dual Eligibles:  2018 (OEI-05-18-00240)  15 
     
   
above in Exhibit 4.  Seven of these eight drugs were also on the list of 
drugs with low inclusion rates in our 2016 report. 
There are multiple potential reasons why a commonly used drug might be 
included by 75 percent or less of formularies: 
  Two of these drugscarisoprodol and methocarbamolare on 
CMSs list of Part D medications that are high-risk for the 
elderly.38 
  The two drugs above and a third drugglyburideare listed by 
the American Geriatrics Society as being potentially inappropriate 
for older adults.39 
  The American Geriatrics Society also cautions against certain uses 
of proton pump inhibitor drugs (PPIs) and drugs with strong 
anticholinergic properties.  Dexlansoprazole and esomeprazole 
magnesium are PPIs, and solifenacin succinate has strong 
anticholinergic properties.40 
Dual eligibles can use three options to obtain a nonformulary drug if a 
formulary does not include a particular drug.  All three options require 
dual eligibles to take additional action.  For instance, if dual eligibles wish 
to obtain therapeutically equivalent alternative drugs that are included by 
their plans formularies, they would need to get new prescriptions from 
their doctors.  Dual eligibles may also go through an appeals process to 
obtain coverage of nonformulary drugs by submitting statements of 
medical necessity from their physicians.41  Finally, dual eligibles may 
switch to Part D plans with formularies that include their drugs, with the 
new coverage becoming effective the following month.42 
                                                 
38 This listUse of High-Risk Medications in the Elderly:  High-Risk Medications 
is part of the Healthcare Effectiveness and Information Set national drug code measures 
published by the National Committee for Quality Assurance.  A drug that is listed as 
being high risk for the elderly is one that has a high risk of serious side effects in that 
population.  CMS uses its prescription data and this medication list to calculate the 
percentage of Medicare beneficiaries who received at least one high-risk medication in 
the past year.  CMS publishes this percentage and other measures of Part D patient safety 
so that Medicare beneficiaries can make informed decisions in choosing Part D plans for 
their prescription drug coverage.  National Committee on Quality Assurance, HEDIS 
2012 NDC List.  Accessed at http://www.cms.gov/Medicare/Prescription-Drug-Coverage/ 
PrescriptionDrugCovContra/Downloads/MemoPatientSafetyMeasures_071610.pdf on 
May 31, 2018. 
39 The American Geriatrics Society, American Geriatrics Society 2015 Updated Beers 
Criteria for Potentially Inappropriate Medication Use in Older Adults, 2015. 
40 Ibid. 
41 CMS, PDBM, ch. 18,  30.2.2. 
42 Ibid., ch. 3,  30.3.2. 
Part D Plans Generally Include Drugs Commonly Used by Dual Eligibles:  2018 (OEI-05-18-00240)  16 
     
   
The Percentage of Commonly Used Drugs To Which 
Plan Formularies Applied Utilization Management 
Tools Increased Slightly Between 2017 and 2018 
For the unique drugs that compose the list of commonly used drugs, the 
percentage to which Part D plan formularies applied utilization 
management tools increased slightly from 28 percent in 2017 to 29 percent 
in 2018.  There was not much of a difference between plans with 
premiums below the regional benchmarks and those with premiums above 
those benchmarks; formularies for the two groups of plans used utilization 
management tools for 26 percent and 31 percent, respectively, of their 
drugs.  See Exhibit 5 for a breakdown of the percentage of unique drugs to 
which Part D plan formularies apply utilization management tools in 2017 
and 2018. 
Exhibit 5:  Part D Plan Formularies Application of Utilization Management Tools to 
Commonly Used Drugs, 2017 and 2018 
Percentage of Unique Drugs  Number of  Number of 
Percentage of  Percentage of 
to Which Utilization  2017 Part D  2018 Part D 
2017 Part D Plan  2018 Part D Plan 
Management Tools Are  Plan  Plan 
Formularies  Formularies 
Applied  Formularies  Formularies 
Greater than 40%  60  16%  78  20% 
30% to 39%  85  23%  130  34% 
20% to 29%  140  38%  90  23% 
10% to 19%  66  18%  66  17% 
Less than 10%  18  5%  22  6% 
     Totals  369  100%  386  100% 
Source:  OIG analysis of formulary inclusion of drugs commonly used by dual eligibles, 2018. 
Although utilization management tools can restrict beneficiaries access to 
drugs, they are important tools for managing costs in Medicare and 
ensuring appropriate utilization of drugs.  For example, in 2013, CMS set 
forth expectations for reviews of opioid overutilization to help ensure that 
opioids are appropriately prescribed and used.  As a result, formularies 
application of utilization management controls to oxycodone HCl/ 
acetaminophen drugs increased by 30 percent in 2013.43 
The percentage of drugs for which formularies applied the utilization 
management tools of quantity limits, prior authorization, or step therapy44 
changed slightly between 2017 and 2018.  Formularies applied quantity 
limits to 26 percent of drugs in 2018a 2 percentage point increase from 
                                                 
43 CMS, Supplemental Guidance Related to Improving Drug Utilization Review Controls 
in Part D, September 6, 2012.  Accessed at https://www.cms.gov/Medicare/Prescription-
Drug-Coverage/PrescriptionDrugCovContra/Downloads/HPMSSupplementalGuidance 
Related-toImprovingDURcontrols.pdf on May 30, 2018. 
44 See footnote 3 for explanations of quantity limits, prior authorization, and step therapy. 
Part D Plans Generally Include Drugs Commonly Used by Dual Eligibles:  2018 (OEI-05-18-00240)  17 
     
   
2017, required prior authorization for 4 percent of drugs, and required 
step therapy for 1 percent of unique drugs. 
The rate at which plan formularies apply specific utilization management 
tools varies widely.  In 2018, some formularies applied utilization 
management tools to very few of the unique drugs, whereas at the other 
end of the range, some applied tools to 56 percent of the unique drugs.  
More specifically, formularies apply quantity limits to between 0 and 53 
percent of unique drugs, require prior authorization for between less than 1 
and 12 percent, and require step therapy for between 0 and 11 percent. 
Looking at enrollment across plans provides a slightly different picture 
than looking only at plans themselves.  On average, plan formularies in 
2018 apply utilization management tools to 33 percent of unique drugs.  
However, dual eligibles tend to be enrolled in plans with formularies that 
apply these tools at a slightly lower rate.  In 2018, the median plan 
weighted by dual-eligible enrollment applies such tools to 31 percent of 
unique drugs; in 2017, the figure was 29 percent.  Similarly, the median 
plan weighted by overall Medicare enrollment applies these tools to 
32 percent of unique drugs in 2018; in 2017, the figure was 30 percent. 
Both dual eligibles and Medicare beneficiaries overall tend to be enrolled 
in plans with formularies that apply utilization management tools to 
between 20 and 39 percent of unique drugs.  In 2018, 71 percent of dual 
eligibles and 66 percent of Medicare beneficiaries overall were enrolled in 
plans with formularies in this range.   
The number of Medicare beneficiaries that were enrolled in plans that 
apply utilization management tools to more than 40 percent of unique 
drugs increased substantially in 2018.  In 2017, 8 percent of dual eligibles 
and 13 percent of Medicare beneficiaries overall were enrolled in plans 
that applied utilization management tools to more than 40 percent of 
unique drugs.  This increased to 24 percent and 26 percent respectively in 
2018.  Exhibit 6 shows enrollment in Part D plans by dual eligibles and 
Medicare beneficiaries, as broken down by the percentages at which the 
plans formularies apply utilization management tools. 
   
Part D Plans Generally Include Drugs Commonly Used by Dual Eligibles:  2018 (OEI-05-18-00240)  18 
     
   
Exhibit 6:  Beneficiary Enrollment in Part D Plans by Application of 
Utilization Management Tools to Commonly Used Drugs, 2017 and 2018 
Percentage of Unique  Percentage  Percentage  Percentage  Percentage 
Drugs to Which Plan  of Dual  of Medicare  of Dual  of Medicare 
Formularies Apply  Eligibles  Beneficiaries  Eligibles  Beneficiaries 
Utilization Management  Enrolled,  Enrolled,  Enrolled,  Enrolled, 
Tools   2017  2017  2018  2018 
Greater than 40%  8%  13%  24%  26% 
30% to 39%  37%  39%  29%  37% 
20% to 29%  50%  40%  41%  29% 
10% to 19%  3%  4%  3%  4% 
Less than 10%  2%  3%  2%  3% 
     Totals  100%*  100%  100%  100%* 
Source:  OIG analysis of formulary inclusion of drugs commonly used by dual eligibles, 2018. 
* Percentages do not add to 100 percent because of rounding. 
 
 
   
Part D Plans Generally Include Drugs Commonly Used by Dual Eligibles:  2018 (OEI-05-18-00240)  19 
     
   
CONCLUSION 
When establishing formularies and applying utilization management tools, 
Part D plans need to balance Medicare beneficiaries needs for adequate 
prescription drug coverage with the need to contain costs for plan sponsors 
and for the Part D program.  By law, Part D plan formularies do not have 
to include every available drug.  Rather, to meet CMSs formulary 
requirements, they must include at least two drugs in each therapeutic 
category or class.  For example, for each of the 12 drugs that this report 
identifies as being included by 75 percent or less of Part D plan 
formularies, all Part D plan formularies cover at least 1 therapeutically 
equivalent alternative drug.  Part D plan formularies may also institute 
utilization management tools to ensure appropriate utilization as well as to 
control costs. 
For the drugs commonly used by dual eligibles, we found that the rate of 
formulary inclusion is high with some variation.  On average, Part D plan 
formularies include 96 percent of the commonly used drugs.  Part D plan 
formularies inclusion of the commonly used drugs ranges from 85 percent 
to 100 percent.  Formulary inclusion rates are similar for PDPs and 
MA-PDs.  Further, formularies for Part D plans with premiums below the 
regional benchmark include the commonly used drugs at a rate similar to 
that of Part D plan formularies overall. 
Inclusion rates for the 197 drugs commonly used by dual eligibles are 
largely unchanged compared with those from OIGs 2017 report.  Part D 
plan formularies include roughly the same percentage of these commonly 
used drugs in 2018 as they did in 2017.  Enrollment in plans that cover at 
least 90 percent of unique drugs decreased, with 93 percent of dual 
eligibles enrolled in such plans in 2018 compared to 96 percent of dual 
eligibles in 2017. 
Because some variation exists in Part D plan formularies inclusion of the 
commonly used drugs and in their application of utilization management 
tools to these drugs, some dual eligibles may need to make additional 
efforts to access the drugs they take.  They could appeal prescription drug 
coverage decisions, switch prescription drugs, or switch Part D plans.  
Because these scenarios require additional effort by dual eligibles, they 
may result in administrative barriers to accessing certain prescription 
drugs. 
As mandated by the ACA, OIG will continue to monitor and produce 
annual reports on the extent to which Part D plan formularies cover drugs 
that dual eligibles commonly use.  In addition, OIG will continue to 
monitor Part D plan formularies application of utilization management 
tools to these drugs.  OIG has no recommendations at this time.   
Part D Plans Generally Include Drugs Commonly Used by Dual Eligibles:  2018 (OEI-05-18-00240)  20 
     
   
APPENDIX A 
Section 3313 of the Patient Protection and Affordable Care Act 
of 2010 
SEC. 3313.  OFFICE OF THE INSPECTOR GENERAL STUDIES AND 
REPORTS. 
(a)  STUDY AND ANNUAL REPORT ON PART D FORMULARIES 
INCLUSION OF DRUGS COMMONLY USED BY DUAL 
ELIGIBLES. 
(1)  STUDY.The Inspector General of the Department of Health and 
Human Services shall conduct a study of the extent to which formularies 
used by prescription drug plans and MA-PD plans under Part D include 
drugs commonly used by full benefit dual eligible individuals (as defined 
in section 1935(c)(6) of the Social Security Act (42 U.S.C.  
1396u5(c)(6)). 
(2)  ANNUAL REPORTS.Not later than July 1 of each year (beginning 
with 2011), the Inspector General shall submit to Congress a report on the 
study conducted under paragraph (1), together with such recommendations 
as the Inspector General determines appropriate. 
Part D Plans Generally Include Drugs Commonly Used by Dual Eligibles:  2018 (OEI-05-18-00240)  21 
     
   
APPENDIX B 
List of Manadated OIG Reports Examining Dual Eligible 
Access to Drugs Under Part D 
 
OIG, Part D Plans Generally Include Drugs Commonly Used by Dual 
Eligibles:  2011, OEI-05-10-00390, April 2011 
OIG, Part D Plans Generally Include Drugs Commonly Used by Dual 
Eligibles:  2012, OEI-05-12-00060, June 2012 
OIG, Part D Plans Generally Include Drugs Commonly Used by Dual 
Eligibles:  2013, OEI-15-13-00090, June 2013 
OIG, Part D Plans Generally Include Drugs Commonly Used by Dual 
Eligibles:  2014, OEI-05-14-00170, June 2014 
OIG, Part D Plans Generally Include Drugs Commonly Used by Dual 
Eligibles:  2015, OEI-05-15-00120, June 2015 
OIG, Part D Plans Generally Include Drugs Commonly Used by Dual 
Eligibles:  2016, OEI-05-16-00090, June 2016 
OIG, Part D Plans Generally Include Drugs Commonly Used by Dual 
Eligibles:  2017, OEI-05-17-00016, June 2017 
   
Part D Plans Generally Include Drugs Commonly Used by Dual Eligibles:  2018 (OEI-05-18-00240)  22 
     
   
 
 
APPENDIX C 
Commonly Used Drugs and Rates of Inclusion by Formularies
The 200 Drugs With the Highest Utilization by Dual Eligibles  
*Sample is from the 2012 MCBS.  Projections and confidence intervals are derived from its survey methodology. 
Number of 
Projected  Percentage of 
Sample  95-Percent Confidence  Formularies 
Generic Name  Drug  Formularies 
Size*  Interval*  Including 
Events*  Including Drug 
Drug 
Lisinopril  4,038  20,381,310  18,552,91322,209,708  386  100% 
Omeprazole  4,425  19,707,133  17,636,41221,777,854  386  100% 
Simvastatin  3,677  18,903,811  16,928,64520,878,978  384  99% 
Amlodipine Besylate  3,855  18,789,961  16,676,94220,902,979  386  100% 
Levothyroxine Sodium  4,242  18,298,908  16,405,76820,192,048  386  100% 
Hydrocodone/Acetaminophen  4,494  17,495,817  15,328,94719,662,688  386  100% 
Furosemide  4,123  17,425,375  15,574,61919,276,131  386  100% 
Metformin Hcl  3,045  15,842,128  14,038,92217,645,334  386  100% 
Atorvastatin Calcium  2,305  12,007,784  10,370,26113,645,307  386  100% 
Metoprolol Tartrate  2,554  11,989,842  10,506,45513,473,229  386  100% 
Potassium Chloride  3,020  11,709,300  10,192,73513,225,866  386  100% 
Gabapentin  2,736  11,258,811  9,908,63712,608,985  386  100% 
Nystatin  3,276  10,800,847  7,318,94214,282,752  386  100% 
Warfarin Sodium  2,512  9,504,416  8,097,30010,911,531  386  100% 
Albuterol Sulfate  2,052  9,204,690  7,942,99110,466,390  386  100% 
Hydrochlorothiazide  1,585  9,049,481  7,557,15110,541,811  386  100% 
Insulin  1,469  7,319,078  5,814,5508,823,605  381  99% 
Glargine,hum.Rec.Anlog 
Metoprolol Succinate  1,403  7,260,928  6,108,6398,413,218  385  100% 
Clopidogrel Bisulfate  1,388  7,230,886  6,099,2418,362,532  386  100% 
Losartan Potassium  1,341  7,202,477  5,960,0298,444,926  386  100% 
Citalopram Hydrobromide  1,725  7,093,303  5,960,0738,226,533  386  100% 
Carvedilol  1,486  6,952,455  5,706,9498,197,960  386  100% 
Esomeprazole Magnesium  1,582  6,926,582  5,590,9208,262,244  247  64% 
Pantoprazole Sodium  1,616  6,892,160  4,604,9999,179,321  386  100% 
Tramadol Hcl  1,792  6,807,062  5,819,3727,794,751  386  100% 
Alprazolam  1,608  6,597,576  5,415,5357,779,617  365  95% 
Trazodone Hcl  1,551  6,511,067  4,727,3598,294,774  386  100% 
Glipizide  1,155  6,481,486  5,271,7457,691,227  386  100% 
Atenolol  1,323  6,288,611  5,220,2037,357,019  386  100% 
Promethazine Hcl  1,730  6,256,116  4,504,6158,007,618  384  99% 
Pravastatin Sodium  1,260  6,247,140  4,770,7137,723,567  385  100% 
Part D Plans Generally Include Drugs Commonly Used by Dual Eligibles:  2018 (OEI-05-18-00240)  23 
     
   
Sertraline Hcl  1,543  6,022,241  4,987,7107,056,771  386  100% 
Clonazepam  1,590  5,877,149  4,656,4637,097,835  386  100% 
Quetiapine Fumarate  1,648  5,801,415  4,446,7477,156,082  386  100% 
continued on next page 
The 200 Drugs With the Highest Utilization by Dual Eligibles, continued 
Number of 
Projected  Percentage of 
Sample  95-Percent Confidence  Formularies 
Generic Name  Drug  Formularies 
Size*  Interval*  Including 
Events*  Including Drug 
Drug 
Zolpidem Tartrate  1,345  5,607,270  4,429,0966,785,444  378  98% 
Ranitidine Hcl  1,412  5,450,546  4,356,4596,544,634  386  100% 
Fluticasone/Salmeterol  1,136  5,427,435  4,383,6176,471,253  372  96% 
Montelukast Sodium  1,145  5,240,144  3,928,8156,551,473  386  100% 
Rosuvastatin Calcium  929  5,137,546  4,054,7426,220,350  376  97% 
Oxycodone Hcl/  1,212  4,957,132  3,982,1545,932,110  386  100% 
Acetaminophen 
Clobetasol Propionate  1,507  4,930,172  2,690,0327,170,312  302  78% 
Donepezil Hcl  1,404  4,870,667  4,189,2065,552,128  384  99% 
Lorazepam  1,374  4,837,237  3,946,9935,727,481  386  100% 
Fluticasone Propionate  1,168  4,776,350  4,033,9375,518,762  386  100% 
Oxycodone Hcl  1,188  4,660,197  3,374,3035,946,091  385  100% 
Tamsulosin Hcl  879  4,490,524  3,658,2455,322,803  386  100% 
Memantine Hcl  1,316  4,209,279  3,461,9704,956,589  386  100% 
Prednisone  1,035  4,114,787  3,508,2094,721,364  386  100% 
Bupropion Hcl  951  4,038,001  2,740,3505,335,653  386  100% 
Alendronate Sodium  824  4,002,546  3,172,0234,833,070  386  100% 
Allopurinol  792  3,970,410  3,153,8774,786,944  386  100% 
Duloxetine Hcl  1,062  3,965,375  3,018,6464,912,104  386  100% 
Valsartan  895  3,950,999  3,159,2554,742,743  383  99% 
Divalproex Sodium  1,179  3,864,519  2,625,7435,103,295  386  100% 
Risperidone  1,263  3,822,970  2,947,2174,698,723  386  100% 
Fluoxetine Hcl  832  3,699,624  2,704,1234,695,126  386  100% 
Tiotropium Bromide  718  3,696,364  2,719,5474,673,181  271  70% 
Ibuprofen  1,014  3,690,403  3,130,4684,250,339  386  100% 
Lisinopril/Hydrochlorothiazide  610  3,672,967  2,948,9714,396,963  386  100% 
Isosorbide Mononitrate  781  3,589,706  2,863,6374,315,775  386  100% 
Mirtazapine  930  3,588,107  2,763,5984,412,615  386  100% 
Cyclobenzaprine Hcl  912  3,572,843  2,872,1824,273,504  383  99% 
Aripiprazole  938  3,516,759  2,734,3164,299,201  386  100% 
Clonidine Hcl  782  3,328,949  2,503,2724,154,625  386  100% 
Paroxetine Hcl  731  3,282,143  2,465,2314,099,056  386  100% 
Meloxicam  698  3,220,620  2,481,7593,959,481  386  100% 
Fluocinonide  777  3,165,499  852,6955,478,304  379  98% 
Escitalopram Oxalate  843  3,163,799  2,577,3633,750,234  386  100% 
Part D Plans Generally Include Drugs Commonly Used by Dual Eligibles:  2018 (OEI-05-18-00240)  24 
     
   
Sitagliptin Phosphate  669  3,145,817  2,351,7613,939,873  374  97% 
Levetiracetam  996  3,127,461  2,400,0443,854,879  386  100% 
Famotidine  751  3,076,189  2,392,5083,759,870  382  99% 
continued on next page 
The 200 Drugs With the Highest Utilization by Dual Eligibles, continued 
Number of 
Projected  Percentage of 
Sample  95-Percent Confidence  Formularies 
Generic Name  Drug  Formularies 
Size*  Interval*  Including 
Events*  Including Drug 
Drug 
Diltiazem Hcl  759  3,034,429  2,389,7823,679,076  386  100% 
Pregabalin  647  3,032,962  2,084,1143,981,811  386  100% 
Glimepiride  568  3,027,684  2,309,9133,745,454  386  100% 
Amitriptyline Hcl  651  3,006,497  2,338,9783,674,016  386  100% 
Lovastatin  580  2,905,667  2,303,9283,507,406  384  99% 
Enalapril Maleate  554  2,859,600  2,095,5113,623,689  386  100% 
Diazepam  683  2,859,179  2,145,7643,572,593  386  100% 
Olanzapine  935  2,805,880  2,153,1233,458,637  386  100% 
Polyethylene Glycol 3350  791  2,794,905  2,261,0813,328,728  386  100% 
Morphine Sulfate  671  2,785,883  2,016,5893,555,177  386  100% 
Lamotrigine  792  2,584,433  1,820,5593,348,306  386  100% 
Ciprofloxacin Hcl  710  2,572,783  2,250,6152,894,952  386  100% 
Nitroglycerin  567  2,516,794  1,989,3153,044,272  386  100% 
Digoxin  671  2,499,207  1,849,1803,149,233  386  100% 
Topiramate  768  2,497,034  1,765,5043,228,563  386  100% 
Oxybutynin Chloride  611  2,496,353  1,865,0243,127,681  386  100% 
Insulin Aspart  576  2,457,698  1,734,7413,180,655  277  72% 
Latanoprost  570  2,362,248  1,830,3072,894,189  386  100% 
Azithromycin  656  2,360,326  2,078,8702,641,781  386  100% 
Diclofenac Sodium  564  2,347,071  1,797,7772,896,364  386  100% 
Sulfamethoxazole/ 
Trimethoprim  679  2,316,522  1,948,9472,684,096  386  100% 
Benztropine Mesylate  831  2,315,393  1,755,8852,874,901  385  100% 
Spironolactone  564  2,309,373  1,714,9412,903,804  386  100% 
Celecoxib  536  2,308,905  1,617,0113,000,799  363  94% 
Baclofen  640  2,259,728  1,773,8602,745,596  386  100% 
Hydrocortisone  355  2,228,990  393,0494,064,931  386  100% 
Valsartan/ 
Hydrochlorothiazide  362  2,148,809  1,446,9992,850,620  382  99% 
Ketoconazole  643  2,118,032  1,508,2222,727,841  386  100% 
Buspirone Hcl  544  2,117,000  1,566,4012,667,599  386  100% 
Venlafaxine Hcl  676  2,086,177  1,603,8062,568,547  386  100% 
Ipratropium/Albuterol Sulfate  514  2,071,560  1,613,3402,529,780  379  98% 
Nifedipine  399  2,061,785  1,496,9222,626,648  377  98% 
Part D Plans Generally Include Drugs Commonly Used by Dual Eligibles:  2018 (OEI-05-18-00240)  25 
     
   
Triamterene/ 
Hydrochlorothiazid  434  1,998,788  1,490,9582,506,617  386  100% 
Lidocaine  566  1,991,949  1,504,8482,479,050  386  100% 
Lactulose  478  1,971,518  1,048,5592,894,477  386  100% 
continued on next page 
The 200 Drugs With the Highest Utilization by Dual Eligibles, continued 
Number of 
Projected  Percentage of 
Sample  95-Percent Confidence  Formularies 
Generic Name  Drug  Formularies 
Size*  Interval*  Including 
Events*  Including Drug 
Drug 
Naproxen  475  1,935,742  1,514,9312,356,553  386  100% 
Carbamazepine  557  1,892,355  1,301,9372,482,774  386  100% 
Budesonide/Formoterol  354  1,877,636  1,080,5482,674,725  306  79% 
Fumarate 
Hydralazine Hcl  423  1,870,997  1,381,3262,360,669  386  100% 
Cephalexin  576  1,859,516  1,586,8092,132,222  386  100% 
Amoxicillin  502  1,859,250  1,639,8302,078,670  386  100% 
Carbidopa/Levodopa  524  1,840,512  1,292,4552,388,569  386  100% 
Meclizine Hcl  430  1,825,694  1,314,9792,336,409  386  100% 
Hydroxyzine Hcl  332  1,816,899  683,1332,950,664  368  95% 
Levofloxacin  525  1,815,766  1,491,0412,140,491  386  100% 
Insulin Detemir  424  1,804,441  1,267,9282,340,954  315  82% 
Phenytoin Sodium Extended  565  1,796,703  1,343,9102,249,496  386  100% 
Pioglitazone Hcl  402  1,778,633  1,249,8262,307,440  386  100% 
Losartan/Hydrochlorothiazide  323  1,756,708  1,195,5622,317,854  386  100% 
Propranolol Hcl  441  1,671,564  1,144,3492,198,778  386  100% 
Ropinirole Hcl  342  1,668,001  946,3182,389,683  386  100% 
Triamcinolone Acetonide  417  1,636,176  1,228,1922,044,160  386  100% 
Verapamil Hcl  347  1,604,821  980,0592,229,583  386  100% 
Clozapine  475  1,570,432  374,7312,766,134  386  100% 
Temazepam  400  1,555,608  1,137,3841,973,832  359  93% 
Fenofibrate Nanocrystallized  400  1,535,334  1,046,3342,024,334  376  97% 
Omega-3 Acid Ethyl Esters  342  1,493,157  979,9702,006,343  364  94% 
Terazosin Hcl  281  1,492,288  963,8202,020,756  386  100% 
Fentanyl  447  1,476,511  927,8472,025,175  386  100% 
Tizanidine Hcl  386  1,427,368  969,4961,885,240  386  100% 
Benazepril Hcl  299  1,413,392  933,2121,893,572  385  100% 
Insulin Lispro  332  1,399,742  956,6451,842,840  204  53% 
Finasteride  279  1,368,049  837,8741,898,225  386  100% 
Bimatoprost  236  1,364,658  897,6741,831,642  372  96% 
Mometasone Furoate  313  1,351,763  984,9671,718,558  385  100% 
Ezetimibe  282  1,341,551  937,0051,746,098  386  100% 
Fenofibrate  239  1,324,483  859,1871,789,779  385  100% 
Amoxicillin/Potassium Clav  324  1,313,164  1,018,0281,608,301  386  100% 
Part D Plans Generally Include Drugs Commonly Used by Dual Eligibles:  2018 (OEI-05-18-00240)  26 
     
   
Acetaminophen With Codeine  334  1,301,414  987,3481,615,481  386  100% 
Lansoprazole  298  1,296,387  849,5561,743,219  302  78% 
Brimonidine Tartrate  314  1,282,393  892,1301,672,657  386  100% 
**See Appendix D. 
continued on next page 
 
 
The 200 Drugs With the Highest Utilization by Dual Eligibles, continued 
Number of 
Projected  Percentage of 
Sample  95-Percent Confidence  Formularies 
Generic Name  Drug  Formularies 
Size*  Interval*  Including 
Events*  Including Drug 
Drug 
Solifenacin Succinate  319  1,274,551  822,9051,726,196  284  74% 
Carisoprodol  344  1,266,633  832,5111,700,754  173  45% 
Estradiol  186  1,237,965  694,0431,781,887  386  100% 
Glyburide  210  1,237,276  752,9721,721,581  187  48% 
Gemfibrozil  373  1,226,890  843,0271,610,754  386  100% 
Metoclopramide Hcl  297  1,220,585  817,3321,623,838  386  100% 
Doxycycline Hyclate  367  1,205,416  874,9131,535,919  386  100% 
Estrogens, Conjugated  196  1,205,404  718,9991,691,810  310  80% 
Fluconazole  352  1,200,530  913,8151,487,245  386  100% 
Timolol Maleate  252  1,199,817  791,4361,608,199  386  100% 
Dexlansoprazole  232  1,183,857  561,3131,806,402  201  52% 
Raloxifene Hcl  235  1,183,587  614,7311,752,442  386  100% 
Pramipexole Di-Hcl  263  1,142,484  657,5261,627,442  386  100% 
Sucralfate  366  1,139,606  826,6651,452,547  386  100% 
Metronidazole  331  1,135,808  843,0941,428,522  386  100% 
Bumetanide  278  1,111,267  589,7621,632,772  386  100% 
Alcohol Antiseptic Pads*  153  1,029,885  651,6031,408,167  Supply  Supply 
Doxazosin Mesylate  255  1,029,363  668,4621,390,263  386  100% 
Torsemide  192  1,026,453  640,9001,412,006  378  98% 
Prednisolone Acetate  223  1,022,524  722,2091,322,839  374  97% 
Nph, Human Insulin Isophane  195  1,007,125  587,0601,427,190  386  100% 
Olopatadine Hcl  266  1,006,336  643,4601,369,212  369  96% 
Colchicine  179  1,005,889  639,0221,372,756  386  100% 
Rivastigmine  298  959,298  618,9661,299,630  378  98% 
Niacin  219  957,366  521,2211,393,511  386  100% 
Folic Acid**  243  957,331  612,0861,302,575  Excluded  Excluded 
Haloperidol  308  956,071  643,5171,268,625  386  100% 
Dorzolamide Hcl/Timolol  196  954,636  615,4151,293,858  380  98% 
Maleat 
Olmesartan Medoxomil  162  951,864  475,3321,428,396  296  77% 
Cyclosporine  238  924,140  652,8101,195,471  386  100% 
Ergocalciferol (Vitamin D2)**  258  915,961  611,9111,220,011  Excluded  Excluded 
Part D Plans Generally Include Drugs Commonly Used by Dual Eligibles:  2018 (OEI-05-18-00240)  27 
     
   
Insulin Regular, Human  294  913,137  530,8881,295,387  386  100% 
Ipratropium Bromide  262  904,182  563,9101,244,455  386  100% 
Tolterodine Tartrate  243  902,139  567,8911,236,388  370  96% 
Methocarbamol  202  896,527  592,2491,200,805  226  59% 
**See Appendix D. 
continued on next page 
 
The 200 Drugs With the Highest Utilization by Dual Eligibles, continued 
Number of 
Projected  Percentage of 
Sample  95-Percent Confidence  Formularies 
Generic Name  Drug  Formularies 
Size*  Interval*  Including 
Events*  Including Drug 
Drug 
Lithium Carbonate  310  894,184  460,3921,327,975  386  100% 
Nebivolol Hcl  204  888,540  570,9091,206,171  273  71% 
Ziprasidone Hcl  280  887,738  486,4101,289,066  386  100% 
Phenobarbital  197  878,403  385,1091,371,696  386  100% 
Methadone Hcl  218  875,640  436,8331,314,448  378  98% 
Methylprednisolone  210  870,654  686,9481,054,361  386  100% 
Dicyclomine Hcl  253  869,035  570,3561,167,714  386  100% 
Desvenlafaxine Succinate  192  853,705  189,5891,517,822  381  99% 
Ciclopirox Olamine  201  844,790  240,5771,449,004  371  96% 
Glyburide/Metformin Hcl  191  843,420  311,5081,375,332  166  43% 
Travoprost  210  841,574  569,6161,113,531  359  93% 
Hydroxyzine Pamoate  240  839,497  585,7521,093,241  282  73% 
Methotrexate Sodium  173  829,816  416,3861,243,246  386  100% 
Mupirocin  246  828,189  583,2991,073,078  384  99% 
Hydroxychloroquine Sulfate  166  819,701  443,5391,195,863  386  100% 
Cinacalcet Hcl  215  817,054  330,2641,303,843  386  100% 
Amlodipine Besylate/  216  792,127  436,3681,147,887  371  96% 
Benazepril 
Ramipril  190  784,878  417,9901,151,766  384  99% 
Isosorbide Dinitrate  174  753,498  371,5451,135,451  384  99% 
Ondansetron Hcl  201  752,416  556,573948,260  386  100% 
Dextroamphetamine/  251  740,436  301,1601,179,711  386  100% 
Amphetamine 
Rivaroxaban  191  736,498  393,4451,079,550  296  77% 
Clindamycin Hcl  207  733,660  539,565927,755  386  100% 
Source:  OIG analysis of drugs commonly used by dual eligibles, 2018.   
**See Appendix D. 
   
Part D Plans Generally Include Drugs Commonly Used by Dual Eligibles:  2018 (OEI-05-18-00240)  28 
     
   
APPENDIX D 
Two Drugs Commonly Used by Dual Eligibles and Not Covered 
Under Part D
Generic Name  Reason Excluded Under Part D 
No longer prescribed without 
Folic Acid 
sulfate 
Ergocalciferol (vitamin D)*  Vitamin or mineral product 
2
Source:  OIG analysis of formulary inclusion of drugs commonly used by dual eligibles, 2018. 
 
   
Part D Plans Generally Include Drugs Commonly Used by Dual Eligibles:  2018 (OEI-05-18-00240)  29 
     
   
APPENDIX E 
Formulary Inclusion of Stand-Alone Prescription Drug Plans* 
and Medicare Advantage Prescription Drug Plans**, by Region
Exhibit E-1:  PDP Formularies Inclusion of Commonly Used Drugs, by PDP Region 
PDP  Number of  Average Rate of Drug  Maximum 
State(s)  Minimum Rate 
Region  PDPs  Inclusion by Formularies  Rate 
1  Maine, New Hampshire  24  95%  88%  99% 
Connecticut, Massachusetts, 
2 
Rhode Island, Vermont  22  95%  88%  99% 
3  New York  20  95%  88%  99% 
4  New Jersey  22  94%  88%  99% 
Delaware, the District of 
5 
Columbia, Maryland  21  95%  88%  99% 
6  Pennsylvania, West Virginia  26  95%  88%  99% 
7  Virginia  24  95%  88%  99% 
8  North Carolina  24  94%  88%  99% 
9  South Carolina  22  95%  88%  99% 
10  Georgia  24  95%  88%  99% 
11  Florida  21  95%  88%  99% 
12  Alabama, Tennessee  25  95%  88%  99% 
13  Michigan  24  95%  88%  99% 
14  Ohio  23  95%  88%  99% 
15  Indiana, Kentucky  24  95%  88%  99% 
16  Wisconsin  25  95%  88%  99% 
17  Illinois  24  94%  85%  99% 
18  Missouri  24  95%  88%  99% 
19  Arkansas  21  95%  88%  99% 
20  Mississippi  20  95%  88%  99% 
21  Louisiana  21  95%  88%  99% 
22  Texas  24  94%  85%  99% 
23  Oklahoma  23  94%  85%  99% 
24  Kansas  23  95%  88%  99% 
Iowa, Minnesota, Montana, 
25  Nebraska, North Dakota, 
South Dakota, Wyoming  23  95%  88%  99% 
26  New Mexico  24  94%  85%  99% 
27  Colorado  24  95%  88%  99% 
28  Arizona  23  95%  88%  99% 
29  Nevada  24  95%  88%  99% 
30  Oregon, Washington  22  95%  88%  99% 
31  Idaho, Utah  25  95%  88%  99% 
32  California  25  95%  88%  99% 
33  Hawaii  20  95%  88%  99% 
34  Alaska  19  94%  88%  99% 
Source:  OIG analysis of formularies inclusion of drugs commonly used by dual eligibles, 2018. 
 
*PDP. 
**MA-PD. 
   
Part D Plans Generally Include Drugs Commonly Used by Dual Eligibles:  2018 (OEI-05-18-00240)  30 
     
   
Exhibit E-2:  MA-PD Formularies Inclusion of Commonly Used Drugs, by MA-PD Region 
Average Rate of 
MA-PD  Number of 
State(s)  Drug Inclusion by  Minimum Rate  Maximum Rate 
Region***   MA-PDs 
Formularies 
1  Maine, New Hampshire  55  97%  91%  99% 
Connecticut, Massachusetts, 
2 
Rhode Island, Vermont  99  96%  92%  99% 
3  New York  199  97%  91%  100% 
4  New Jersey  42  96%  89%  98% 
Delaware, the District of Columbia, 
5 
Maryland  40  97%  95%  100% 
6  Pennsylvania, West Virginia  192  97%  91%  100% 
7  North Carolina, Virginia  144  97%  89%  100% 
8  Georgia, South Carolina  112  97%  91%  100% 
9  Florida  283  97%  91%  100% 
10  Alabama, Tennessee  91  97%  95%  98% 
11  Michigan  69  97%  95%  98% 
12  Ohio  127  97%  92%  100% 
13  Indiana, Kentucky  112  97%  94%  100% 
14  Illinois, Wisconsin  157  97%  85%  99% 
15  Arkansas, Missouri  90  97%  91%  100% 
16  Louisiana, Mississippi  65  97%  91%  100% 
17  Texas  159  97%  94%  100% 
18  Kansas, Oklahoma  57  97%  91%  100% 
Iowa, Minnesota, Montana, Nebraska, 
19  North Dakota, South Dakota, 
Wyoming  97  96%  91%  100% 
20  Colorado, New Mexico  62  97%  91%  100% 
21  Arizona  68  97%  95%  100% 
22  Nevada  34  97%  91%  99% 
23  Idaho, Oregon, Utah, Washington  193  97%  92%  100% 
24  California  266  97%  93%  100% 
25  Hawaii  19  97%  95%  100% 
Source:  OIG analysis of formularies inclusion of drugs commonly used by dual eligibles, 2018. 
***Region 26, which covers Alaska, had no MA-PDs available for 2018. 
 
 
Part D Plans Generally Include Drugs Commonly Used by Dual Eligibles:  2018 (OEI-05-18-00240)  31 
     
   
ACKNOWLEDGMENTS 
This report was prepared under the direction of Thomas Komaniecki, 
Regional Inspector General for Evaluation and Inspections in the Chicago 
regional office.  
Hilary Slover served as the team leader for this study.  Central office staff 
who provided support include Kevin Farber, Meghan Riggs, Christine 
Moritz, and David Tawes. 
Part D Plans Generally Include Drugs Commonly Used by Dual Eligibles:  2018 (OEI-05-18-00240)  32 
     
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