DEPARTMENT OF HEALTH AND HUMAN SERVICES 

OFFICE OF INSPECTOR GENERAL 

WASHINGTON, DC 202 01 

SEP \ .·6 2015 


TO: Andrew M. Slavitt 

Acting Administrator 


Centers for Medicare & Medicaid Services 


FROM: Suzanne M.w.:rin 

Deputy Inspec~ G-enet:al 

for Ev..,a.J...tmtion ancl' Inspections 

SUBJECT: 	 Recommendation Followup Memorandum Report: States' Collection of 

Rebates for Drugs Paid Through Medicaid Managed Care Organizations 

Has Improved, OEI-05-14-00431 

This memorandum report provides information about States' collection of rebates for 

drugs paid through Medicaid managed care organizations (MCOs). A 2012 Office of 

Inspector General (OIG) report found that 10 States were not collecting rebates for drugs 

paid through MCOs (hereinafter referred to as MCO rebates), despite new requirements 

in the Affordable Care Act (ACA) to do so. If States do not collect all eligible MCO 

rebates, then States and the Federal Government both fail to realize all of the savings they 

are owed under the Medicaid Drug Rebate Program. This memorandum report provides 

an update on the status of States' collection ofMCO rebates. 

SUMMARY 

OIG found that nearly all (35 of37) States that pay for drugs through MCOs collected 

rebates for these drugs between July 1, 2013, and June 30,2014, as required by ACA. 1 

These 35 States collected $7.5 billion in MCO rebates during that time. 

This represents a significant improvement compared to OIG's previous finding that only 

12 of 22 States paying for drugs through MCOs were collecting rebates for those drugs in 

2011. 2 Although the 10 States that were not collecting rebates in 2011 are now doing so , 

we found additional States that are not collecting the rebates. Moreover, we found that 

nine States collected some eligible MCO rebates, but not all of them. States that are not 

collecting all eligible MCO rebates fail to realize all of the savings they are owed under 

1 ACA , P.L. No . 111-148 § 250l(c); 42 U.S .C. § 1396b(m)(2) and 42 U.S .C. § 1396r-8(b)(l). 2 OIG, States ' Collection ofRebates for Drugs Paid Through Medicaid Managed Care Organizations, 

OEI-03-11-00480, September 2012. 
 

 

 

 

 

Page 2 – Andrew M. Slavitt 

the Medicaid Drug Rebate Program. This also affects the Federal Government because it 

does not receive its share of these eligible, but uncollected, MCO rebates. 

One specific challenge that States reported as hampering their ability to collect all 

eligible MCO rebates was difficulty in collecting rebates for drugs administered by 

physicians (hereinafter referred to as physician-administered drugs). A drug’s National 

Drug Code (NDC) is a necessary component for invoicing a drug rebate, and States 

reported that they could not reliably obtain the NDCs from claims for 

physician-administered drugs.3 

BACKGROUND 

Medicaid Prescription Drug Coverage 

All 50 States and the District of Columbia (hereinafter referred to as States) offer 

outpatient prescription drug coverage as part of their Medicaid benefit packages. 

In 2013, Medicaid reimbursement for covered outpatient drugs totaled approximately 

$35 billion.4, 5 Covered outpatient drugs include drugs dispensed directly to patients at 

pharmacies (hereinafter referred to as pharmacy drugs) and physician-administered drugs. 

States use two primary payment models to pay for drugs: fee-for-service (hereinafter 

referred to as Medicaid FFS) and MCOs. Under the Medicaid FFS model, States pay 

pharmacies and providers directly for each service. Under the MCO model, States 

prospectively pay MCOs a fixed monthly amount for each Medicaid beneficiary, 

regardless of whether a beneficiary gets services during the month. States may choose to 

use one payment model or both. 

Medicaid Drug Rebate Program 

The Omnibus Budget Reconciliation Act of 1990 established the Medicaid Drug Rebate 

Program.6 The program requires that, for covered outpatient drugs (hereinafter referred 

to as drugs) to be eligible for Federal financial participation through Medicaid, 

manufacturers must pay rebates to States on these drugs when the drugs are dispensed to 

Medicaid beneficiaries and paid for by Medicaid.7 States essentially share a portion of 

these rebates with the Federal government.8 

In 2010, ACA expanded the Medicaid Drug Rebate Program to require payment of 

rebates for drugs paid through MCOs if a MCO is responsible for coverage of such 

3

 The NDC is a unique three-segment number that the Food and Drug Administration assigns to a drug
 

product. NDCs serve as universal product identifiers for drugs. 

4

 The term “covered outpatient drug” is defined at 42 U.S.C. § 1396r-8(k)(2). 

5

 OIG analysis of data from the Centers for Medicare & Medicaid Services (CMS) Medicaid Budget and 

Expenditure System (MBES) and analysis of Medicaid State utilization data, June 2015. We combined 

Medicaid FFS expenditures (from MBES) and MCO expenditures (from Medicaid State utilization data). 

This estimate does not reflect Medicaid rebates. 

6 The Omnibus Budget Reconciliation Act of 1990, P.L. No. 101-508, § 4401; 42 U.S.C. § 1396r-8. 

7 42 U.S.C. §§ 1396r-8(a)(1) and 1396r-8(b)(1). 

8 42 U.S.C. §§ 1396r-8(b)(1).
 

States’ Collection of MCO Drug Rebates Has Improved (OEI-05-14-00431) 
 

 

 

Page 3 – Andrew M. Slavitt 

drugs.9 Prior to the ACA, only drugs paid through Medicaid FFS were subject to rebates 

under the Medicaid Drug Rebate Program. 

MCO Rebates 

To collect MCO rebates, States determine the amount of MCO rebates owed for each 

quarter and send invoices to manufacturers. This process begins when MCOs send States 

data containing the number of units of each drug (by NDC) dispensed to their 

beneficiaries in the quarter.10 Using these data, States determine the total number of units 

reimbursed by MCOs for each NDC.11 States then multiply the total number of units by 

the NDC’s unit rebate amount (URA) to determine the total quarterly amount of MCO 

rebates owed for each NDC. Finally, States send invoices to manufacturers reflecting the 

total quarterly amount of MCO rebates owed for the manufacturers’ respective NDCs. 

To calculate and invoice MCO rebates, States need to know which specific NDCs were 

dispensed or administered to MCO beneficiaries. This information is readily available in 

MCO data on pharmacy drugs because providers use NDCs to bill for pharmacy drugs. 

To bill for physician-administered drugs, however, providers use Healthcare Common 

Procedure Coding System (HCPCS) codes. Because a single HCPCS code may be 

associated with more than one NDC for a given physician-administered drug, States 

cannot always determine from the MCO data which specific drugs were actually 

administered unless providers have also included NDCs on claims when billing. 

Accordingly, the Deficit Reduction Act of 2005 essentially required that States require 

providers to submit NDCs on physician-administered drug claims to secure rebates.12 

Related Office of Inspector General Work 

In September 2012, OIG published a review of States’ collection of rebates for drugs paid 

through MCOs.13 OIG found that, of 22 States paying for drugs through MCOs, 10 had 

not invoiced manufacturers for MCO rebates in 2011. OIG recommended that CMS 

follow up with these 10 States and take action to enforce rebate collection if necessary. 

CMS concurred with this recommendation and noted steps it had taken to address the 

issue. 

In August 2014, OIG published a review of the Medicaid Drug Rebate dispute resolution 

process.14 OIG found that although drug rebate disputes only involve a small percentage 

of rebate dollars, certain types of disputes occur frequently within this small percentage. 

States reported that poor-quality claims data lead to disputes regarding 

physician-administered drugs. To address this finding, OIG recommended that CMS 

work with States to improve the quality of claims data submitted by providers and 

pharmacies. 

9

 ACA, P.L. No. 111-148 § 2501(c); 42 U.S.C. § 1396b(m)(2) and 42 U.S.C. § 1396r-8(b)(1). 

10 CMS, State Medicaid Director Letter #10-006, April 22, 2010. 11 Each drug has an NDC. NDCs contain information that States need to calculate and invoice MCO 

rebates, including a drug’s manufacturer and dosage form and strength.
 12 42 U.S.C. § 1396r-8(a)(7); 42 CFR § 447.520’. 13 OIG, States’ Collection of Rebates for Drugs Paid Through Medicaid Managed Care Organizations,
 

OEI-03-11-00480, September 2012. 

14 OIG, Medicaid Drug Rebate Dispute Resolution Could Be Improved, OEI-05-11-00580, August 2014. 

States’ Collection of MCO Drug Rebates Has Improved (OEI-05-14-00431) 
 

Page 4 – Andrew M. Slavitt 

In March 2015, OIG published an audit reviewing Oregon’s compliance with the 

requirement to collect MCO rebates—specifically, examining Oregon’s collection of 

MCO rebates for physician-administered drugs.15 The audit found that the State did not 

invoice manufacturers for rebates because during the period the audit reviewed, the 

State’s Medicaid Management Information System did not have an edit to ensure that 

NDCs were present and valid in the MCO drug utilization data for 

physician-administered drugs. 

METHODOLOGY 

Scope 

This report examines the status of States’ collection of MCO rebates between July 1, 

2013, and June 30, 2014. This report does not cover States’ collection of rebates for 

drugs paid through Medicaid FFS. We did not attempt to quantify the amount of 

rebate-eligible drugs for which States were unable to invoice and collect. This report also 

does not break down rebate amounts by pharmacy drugs and physician-administered 

drugs. 

Data Collection and Analysis 

To address our objective, we conducted electronic surveys and structured interviews with 

State Medicaid agencies in November and December 2014. 

State surveys. In November 2014, we surveyed 51 States. We sent the surveys to State 

Medicaid pharmacy directors with instructions to delegate to other State staff and rebate 

vendors as appropriate. We asked whether States paid for either pharmacy drugs or 

physician-administered drugs through MCOs, and whether States had invoiced and 

collected rebates for those drugs between July 1, 2013 and June 30, 2014. We also asked 

States to provide the amount of MCO rebates that were invoiced and collected for each of 

the four quarters between July 1, 2013 and June 30, 2014. We received responses from 

all 51 States, a 100-percent response rate. 

Of the 51 States, 42 reported that they paid for all or some drugs through MCOs between 

July 1, 2013, and June 30, 2014, whereas 9 States reported that they did not pay for drugs 

through MCOs. Table 1, on the next page, shows the breakdown of all 51 States. 

15 OIG, Oregon Did Not Bill Manufacturers for Rebates for Physician-Administered Drugs Dispensed to 

Enrollees of Medicaid Managed-Care Organizations, A-09-13-02037, March 2015. 

States’ Collection of MCO Drug Rebates Has Improved (OEI-05-14-00431) 
   

 

 

 

Page 5 – Andrew M. Slavitt 

Table 1: States Paying for Prescription Drugs through Medicaid MCOs 

Use of MCOs for Prescription Drugs Number of States 

Paid for all or some drugs through 

MCOs 

Paid for drugs through MCOs (i.e., pharmacy 

drugs and/or physician-administered drugs) 

37 

Paid for only a small volume of drugs through 

MCOs 

4 

Paid for drugs through an MCO that is not 

eligible for rebates 

1 

Did not pay for any drugs through MCOs 9 

Total 51 

Source: OIG survey of States, 2014. 

We excluded 5 of the 42 States that paid for drugs through MCOs, leaving 37 States in 

our analysis. Of the five States we excluded, four were excluded because they paid for 

only a small volume of drugs through MCOs (e.g., for a small number of beneficiaries 

enrolled in Program of All-Inclusive Care for the Elderly (PACE) plans).16 These States 

reported that they are not collecting MCO rebates because it is not cost-effective to do so 

for such a small volume of drugs; the States said that the administrative cost to calculate, 

track, and receive rebates would exceed the benefit of collecting MCO rebates. We 

excluded the remaining State because it paid for drugs through an MCO that was not 

eligible for rebates. In this case, the MCO purchased drugs at discounted prices through 

the 340B Drug Pricing Program and such drugs are not subject to rebates under the 

Medicaid Drug Rebate Program.17 

For the nine States that reported that they did not pay for drugs through MCOs, we 

confirmed that this was the case by checking three CMS data sources for any evidence 

suggesting that the States had paid for drugs through MCOs. These three sources were 

CMS’s National Summary of State Medicaid Managed Care Programs for 2012, 

the CMS-64 expenditure data for each State, and the Medicaid drug utilization for each 

State.18 We checked the 2012 summary for any listed plans with outpatient drug 

coverage.19 We also checked CMS-64 expenditure data and Medicaid drug utilization 

data—both of which States submit to CMS—for any dollar amounts associated with 

16 According to CMS’s PACE Fact Sheet, a PACE organization is a not-for-profit private or public entity 

that is engaged primarily in providing comprehensive medical and social services. PACE services use an 

interdisciplinary team approach in an adult day health center. Available online at 

https://www.cms.gov/Medicare/Health-Plans/pace/downloads/PACEFactSheet.pdf. 17 Covered outpatient drugs are not subject to rebates under the Medicaid Drug Rebate Program if they are 

dispensed by MCOs and subject to discounts under the Health Resource and Services Administration’s 

340B Drug Pricing Program. See 42 U.S.C. § 1396r-8(j)(1). 

18 States use Form CMS-64 to report their expenditures for Medicaid and the Children’s Health Insurance 

Program. 

19 This was the most current available version of the report. 

States’ Collection of MCO Drug Rebates Has Improved (OEI-05-14-00431) 
 

 

 

 

 

Page 6 – Andrew M. Slavitt 

drugs paid through MCOs. If we found any such evidence, we contacted the State to 

resolve the discrepancy and confirm that it was not paying for drugs through MCOs.20 

State interviews. In December 2014, we conducted structured interviews with staff from 

the 37 States that paid for drugs using MCOs and were not among the States we 

excluded. 

Limitations 

The findings are based on survey and interview responses provided by States. We did not 

verify the accuracy of the rebate amounts reported by States. The rebate amounts in this 

report were current as of December 2014, when we completed our data collection. 

Standards 

This report was conducted in accordance with the Quality Standards for Inspection and 

Evaluation issued by the Council of the Inspectors General on Integrity and Efficiency. 

RESULTS 

Nearly all 37 States in this analysis collected MCO rebates, which represents an 

increase from the number of States collecting rebates in 2011 

Thirty-five of the thirty-seven States in this analysis collected MCO rebates, representing 

a higher proportion of States collecting rebates than in OIG’s 2012 report. That report 

found that only 12 of 22 States paying for drugs through MCOs collected MCO rebates in 

2011.21 All 10 of the States that were not collecting MCO rebates in 2011 reported that 

they are now doing so.22 OIG previously recommended that CMS follow up with those 

10 States to ensure that they collect MCO rebates as required.23 CMS concurred with this 

recommendation and noted steps it had taken to address the issue. 

However, 9 of the 35 States that collected MCO rebates reported to us that they were 

unable to do so for all rebate-eligible drugs paid through MCOs. Although these States 

invoiced and collected some MCO rebates, they reported that they could not invoice all 

eligible MCO rebates. Five of these nine States did not invoice or collect MCO rebates 

for any physician-administered drugs. 

Two of the thirty-seven States in this analysis did not invoice or collect any MCO 

rebates. One of the two States was not able to load drug claim data sent by MCOs into its 

claims processing system because its system required updates to accommodate the 

MCO data. The other State received inaccurate and incomplete information from its 

20 In some cases, we found plans with outpatient drug coverage listed in CMS’s National Summary report 

for States that reported that they did not pay for drugs through MCOs. When we contacted them, however,
 

these States reported that the listed plans either did not cover outpatient drugs or had been discontinued.
 21 OIG, States’ Collection of Rebates for Drugs Paid Through Medicaid Managed Care Organizations,
 

OEI-03-11-00480, September 2012. 

22 See Appendix C in OEI-03-11-00480. These 10 States are California, the District of Columbia, Florida,
 

Hawaii, Kansas, Mississippi, New Mexico, Virginia, Washington, and West Virginia. 

23 OIG, States’ Collection of Rebates for Drugs Paid Through Medicaid Managed Care Organizations,
 

OEI-03-11-00480, September 2012. 

States’ Collection of MCO Drug Rebates Has Improved (OEI-05-14-00431) 
Page 7 – Andrew M. Slavitt 

MCO. Both States were in the process of resolving these issues and planned to invoice 

for MCO rebates as soon as possible. 

See Appendix A for details about which States collected MCO rebates for pharmacy 

drugs and physician-administered drugs. 

States collected approximately $7.51 billion of $8.77 billion invoiced in MCO rebates 

The thirty-five States that reported collecting MCO rebates collected approximately 

$7.51 billion of the $8.77 billion they invoiced. Figure 1 shows the total amount of 

MCO rebates invoiced and collected between July 1, 2013, and June 30, 2014, by quarter. 

The amounts reported represent MCO rebates for pharmacy drugs and 

physician-administered drugs reported by States. 

Figure 1: MCO Rebates Invoiced and Collected between July 1, 2013, and June 30, 2014 

(in billions) 

Q3, 2013 Q4, 2013 Q1, 2014 Q2, 2014 

Invoiced $1.91 $2.04 $2.23 $2.60 

Collected $1.85 $1.91 $2.09 $1.67

 $-

 $0.5

 $1.0

 $1.5

 $2.0

 $2.5

 $3.0 

Billions of dollars 

97% 

collected 

94% 

collected 

94% 

collected 

64% 

collected* 

Source: OIG survey of States, 2014. 

Note: These quarters represent the four quarters between July 1, 2013, and June 30, 2014. 

* The percentage collected in the second quarter of 2014 is lower than for other quarters because States were still waiting for manufacturer 

payments for that quarter at the time we collected our data. 

Individual States’ collection rates for the same period ranged from 49 percent to 

100 percent, with an average of 84 percent. See Appendix B for State-specific details. 

These percentages will likely change over time; States told us that invoice amounts and 

collection amounts are constantly in flux because of continual adjustments and 

recalculations (e.g., URA adjustments). States also reported that because of manufacturer 

disputes, they did not routinely collect 100 percent of the amounts they had invoiced. 

States’ Collection of MCO Drug Rebates Has Improved (OEI-05-14-00431) 
 

 

 

 

 

 

 

Page 8 – Andrew M. Slavitt 

Prior OIG work has highlighted the role that manufacturer disputes play in uncollected 

Medicaid drug rebates.24, 25 

Although most States are now collecting MCO rebates, problems persist in 

collecting MCO rebates for physician-administered drugs 

Nine States reported that they had problems collecting MCO rebates for 

physician-administered drugs. The primary problem that States reported was that they 

could not reliably obtain NDCs from physician-administered drug claims. States need to 

know which specific NDCs were associated with drugs administered to MCO 

beneficiaries to calculate and invoice MCO rebates for such drugs. See Appendix A for 

details about which States were able to collect MCO rebates for physician-administered 

drugs. 

Some States could not reliably obtain NDCs from claims for physician-administered 

drugs because their MCOs sent NDC data in file formats that were incompatible with 

States’ systems for processing MCO claims. States reported that to resolve these 

technical issues, they were working to modify their systems to accept the files from 

MCOs. 

One State could not reliably obtain NDCs from claims for physician-administered drugs 

because hospitals were not always reporting them to MCOs. The State noted that a 

claims-processing edit for MCO claims did not always force hospitals to enter the NDC, 

so many claims were submitted without NDCs. This State reported that it plans to 

implement a claims processing edit that will be more effective in forcing hospitals to 

report NDCs. 

Previous OIG work found similar issues related to rebates for physician-administered 

drugs. A 2015 OIG audit in one State found that the State was unable to collect such 

rebates because it was not consistently receiving NDCs from MCOs.26, 27 Further, in a 

2014 OIG report, States reported that even when providers submitted NDCs for 

physician-administered drugs, those NDCs were not always correct.28 States need correct 

NDCs to create accurate rebate invoices, but they reported that they had limited ability to 

determine whether the NDCs submitted by providers were correct. 

24 OIG, States’ Collection of Rebates for Drugs Paid Through Medicaid Managed Care Organizations,
 

OEI-03-11-00480, September 2012. 

25 OIG, Medicaid Drug Rebate Dispute Resolution Could Be Improved, OEI-05-11-00580, August 2014. 26 OIG, Oregon Did Not Bill Manufacturers for Rebates for Physician-Administered Drugs Dispensed to
 

Enrollees of Medicaid Managed-Care Organizations, A-09-13-02037, March 2015. 27 Oregon is not one of the nine States that reported problems collecting MCO rebates for 

physician-administered drugs. The OIG audit was performed on data from 2010, and the audit noted that
 

Oregon planned to correct its process. During data collection for this report, Oregon reported it was able to
 

invoice and collect MCO rebates for physician-administered drugs for the timeframe of July 1, 2013, to
 

June 30, 2014. 

28 OIG, Medicaid Drug Rebate Dispute Resolution Could Be Improved, OEI-05-11-00580, August 2014. 

States’ Collection of MCO Drug Rebates Has Improved (OEI-05-14-00431) 
 

Page 9 – Andrew M. Slavitt 

CONCLUSION 

States have made progress in collecting MCO rebates since 2011, but not all States are 

collecting MCO rebates as required. Although the 10 States that were not collecting 

MCO rebates in 2011 report are now doing so, we found additional States that are not 

collecting MCO rebates. Moreover, we found that nine States collected some, but not all, 

eligible MCO rebates. States that are not collecting all eligible MCO rebates fail to 

realize all of the savings that they are owed under the Medicaid Drug Rebate Program. 

This also affects the Federal government because it does not receive its share of these 

eligible, but uncollected, MCO rebates. In keeping with OIG’s previous 

recommendation, CMS should continue to work to ensure that all States are invoicing and 

collecting MCO rebates. 

One specific challenge that States reported as hampering their ability to collect all 

eligible rebates for drugs paid through MCOs related to collecting rebates for 

physician-administered drugs. States reported that they could not reliably obtain the 

NDCs from claims for physician-administered drugs, and these NDCs are a necessary 

component for invoicing rebates for these drugs. A 2014 OIG study on the Medicaid 

Dispute Resolution Program recommended that CMS work with States to improve the 

quality of claims data submitted by providers and pharmacies, specifically noting NDCs 

for physician-administered drugs as an example. We continue to encourage CMS to 

address that recommendation in light of this report’s finding that States still struggle to 

obtain NDCs from claims for physician-administered drugs. 

This report is being issued directly in final form because it contains no new 

recommendations. If you have comments or questions about this report, please provide 

them within 60 days. Please refer to report number OEI-05-14-00431 in all 

correspondence. 

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Page 10 – Andrew M. Slavitt 

APPENDIX A 

States’ Coverage of Drugs through MCOs and Related Rebate Collection 

State MCOs Cover 

Pharmacy Drugs? 

Collected MCO 

Rebates for 

Pharmacy Drugs? 

MCOs Cover 

PhysicianAdministered Drugs? 

State Collected MCO 

Rebates for PhysicianAdministered Drugs? 

State Collected 

Eligible MCO 

Rebates? 

Arizona Yes  Yes  

California Yes ~ Yes ~ ~

D.C. Yes  Yes  

Delaware No N/A Yes  

Florida Yes  Yes  

Georgia Yes  Yes  

Hawaii Yes  Yes  

Iowa No N/A Yes  

Illinois Yes  Yes  

Indiana No N/A Yes  

Kansas Yes  Yes  

Kentucky Yes  Yes  

Louisiana Yes  Yes  

Massachusetts Yes  Yes  ~

Maryland Yes  Yes  

Michigan Yes  Yes  

Minnesota Yes  Yes  

Mississippi Yes  Yes  

North Dakota Yes  Yes  

Nebraska No N/A Yes ~ ~

New Hampshire Yes  Yes  

New Jersey Yes  Yes  ~

New Mexico Yes  Yes  

Nevada Yes  Yes  

New York Yes  Yes  

Ohio Yes  Yes  ~

Oregon Yes  Yes  

Pennsylvania* Yes ~ Yes ~ ~

Rhode Island Yes  Yes  ~

South Carolina Yes ~ Yes  ~

Tennessee No N/A Yes  

Texas Yes  Yes  

Utah Yes  Yes  

Virginia Yes  Yes  

Washington Yes  Yes  

Wisconsin Yes  Yes  ~

West Virginia Yes  Yes  

Source: OIG survey of States, 2014. 

* Pennsylvania collected MCO rebates both for pharmacy drugs and physician-administered drugs, but State staff did not know whether 

the State had collected all eligible MCO rebates for the two categories of drugs. Accordingly, we categorized Pennsylvania as having 

invoiced for “some (but not all)” eligible MCO rebates. 

Key:  = State did not collect any MCO rebates

= State invoiced for all eligible MCO rebates and collected MCO rebates
 

~ = State invoiced for some (but not all) eligible MCO rebates and collected MCO rebates
 

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Page 11 – Andrew M. Slavitt 

APPENDIX B 

MCO Rebates Collected by States between July 1, 2013, and June 30, 2014 

State Amount Invoiced Amount Collected Percentage of 

Invoiced Amount 

Collected 

Arizona $318,181,037 $274,786,225 86% 

California $454,759,133 $392,871,243 86% 

D.C. $35,080,120 $26,695,115 76% 

Delaware $8,223,331 $6,107,223 74% 

Florida $282,625,487 $274,956,704 97% 

Georgia $134,029,479 $128,760,597 96% 

Hawaii $78,788,049 $62,479,766 79% 

Iowa $0 $0 -

Illinois $109,895,722 $81,658,417 74% 

Indiana $3,990,567 $3,357,553 84% 

Kansas $217,934,623 $204,251,081 94% 

Kentucky $264,068,108 $217,544,048 82% 

Louisiana $116,247,767 $116,138,682 100% 

Massachusetts $198,809,119 $140,726,603 71% 

Maryland $157,400,842 $154,333,129 98% 

Michigan $244,735,792 $239,563,273 98% 

Minnesota $222,807,221 $184,121,166 83% 

Mississippi $72,044,530 $56,836,455 79% 

North Dakota $1,271,338 $620,901 49% 

Nebraska $1,057,212 $759,009 72% 

New Hampshire $0 $0 -

New Jersey $361,829,523 $336,149,505 93% 

New Mexico $24,317,198 $21,138,285 87% 

Nevada $20,897,677 $19,520,688 93% 

New York $1,896,706,923 $1,730,274,331 91% 

Ohio $486,155,452 $419,767,906 86% 

Oregon $132,408,122 $120,703,594 91% 

Pennsylvania $1,080,767,357 $853,398,423 79% 

Rhode Island $47,230,168 $44,775,094 95% 

South Carolina $138,174,280 $127,844,605 93% 

Tennessee $16,800,548 $12,521,800 75% 

Texas $1,155,443,626 $864,772,615 75% 

Utah $41,306,860 $38,461,080 93% 

Virginia $226,583,055 $193,319,794 85% 

Washington $176,412,325 $124,493,625 71% 

Wisconsin $2,010,590 $1,725,421 86% 

West Virginia $42,085,197 $32,181,813 76% 

Source: OIG survey of States, 2014. 

States’ Collection of MCO Drug Rebates Has Improved (OEI-05-14-00431)