Department of Health and Human Services 

OFFICE OF 

INSPECTOR GENERAL 

Inspector General 

April 2004 

OEI-03-02-00660 

MEDICAID REBATES FOR 

PHYSICIAN-ADMINISTERED 

DRUGS 
Office of Inspector General

http://oig.hhs.gov 

The mission of the Office of Inspector General (OIG), as mandated by Public Law 95-452, 

as amended, is to protect the integrity of the Department of Health and Human Services 

(HHS) programs, as well as the health and welfare of beneficiaries served by those 

programs. This statutory mission is carried out through a nationwide network of audits, 

investigations, and inspections conducted by the following operating components: 

Office of Audit Services 

The OIG's Office of Audit Services (OAS) provides all auditing services for HHS, either by 

conducting audits with its own audit resources or by overseeing audit work done by others. 

Audits examine the performance of HHS programs and/or its grantees and contractors 

in carrying out their respective responsibilities and are intended to provide independent 

assessments of HHS programs and operations in order to reduce waste, abuse, and 

mismanagement and to promote economy and efficiency throughout the department. 

Office of Evaluation and Inspections 

The OIG's Office of Evaluation and Inspections (OEI) conducts short-term management 

and program evaluations (called inspections) that focus on issues of concern to the 

department, the Congress, and the public. The findings and recommendations contained 

in the inspections reports generate rapid, accurate, and up-to-date information on the 

efficiency, vulnerability, and effectiveness of departmental programs. 

Office of Investigations 

The OIG's Office of Investigations (OI) conducts criminal, civil, and administrative 

investigations of allegations of wrongdoing in HHS programs or to HHS beneficiaries 

and of unjust enrichment by providers. The investigative efforts of OI lead to criminal 

convictions, administrative sanctions, or civil monetary penalties. The OI also oversees 

State Medicaid fraud control units, which investigate and prosecute fraud and patient 

abuse in the Medicaid program. 

Office of Counsel to the Inspector General 

The Office of Counsel to the Inspector General (OCIG) provides general legal services to 

OIG, rendering advice and opinions on HHS programs and operations and providing all 

legal support in OIG's internal operations. The OCIG imposes program exclusions and 

civil monetary penalties on health care providers and litigates those actions within the 

department. The OCIG also represents OIG in the global settlement of cases arising 

under the Civil False Claims Act, develops and monitors corporate integrity agreements, 

develops model compliance plans, renders advisory opinions on OIG sanctions to the 

health care community, and issues fraud alerts and other industry guidance. 
� ABSTRACT

Under the Medicaid Drug Rebate Program, manufacturers are 

required to provide rebates on drugs paid for by a State. To receive 

rebates, States must identify the drugs by their national drug code. 

Most States, however, use procedure codes to identify physicianadministered drugs. The States that match procedure codes to 

national drug codes do collect rebates on these drugs. We found that 

in 2001, Medicaid could have saved millions of additional rebate 

dollars if every State had collected rebates for all single-source 

physician-administered drugs and 40 multiple-source physicianadministered drugs. As of March 2003, 24 States did not collect 

rebates on any physician-administered drugs. Our study indicates a 

State’s savings in a single year could exceed the one-time cost of 

implementing system changes needed to collect rebates for these 

drugs. We recommend that the Centers for Medicare & Medicaid 

Services (CMS) continue to encourage all States to collect rebates on 

physician-administered drugs, especially single-source drugs. As part 

of this effort, CMS should encourage cooperation and the sharing of 

information between States that collect rebates for these drugs, and 

States that do not, in order to facilitate rebate collection. CMS 

concurred with our recommendation and is currently facilitating 

information sharing. 

OEI - 03 - 02 - 00660 MEDICAID REBATES FOR P HYSICIAN - A DMINISTERED D RUGS i 
� EXECUTIVE SUMMARY

OBJECTIVES 

(1) To determine whether all State Medicaid agencies collect 

drug manufacturer rebates for all physician-administered drugs. 

(2) To estimate the potential savings that would result if all 

State Medicaid agencies collected drug manufacturer rebates for 

physician-administered drugs. 

BACKGROUND 

The Medicaid program, established under Title XIX of the Social 

Security Act, is administered by States and financed with State 

and Federal funds. Medicaid pays for medical and healthrelated assistance for certain vulnerable and needy individuals 

and families. All 50 States and the District of Columbia provide 

coverage for prescription drugs under the Medicaid program. 

The Medicaid Drug Rebate Program was established in 1990 to 

reduce State and Federal Medicaid expenditures for prescription 

drugs. Under the rebate program, manufacturers are required 

to provide a rebate on drugs paid for by a State. Physicianadministered drugs (drugs that a medical professional 

administers to a patient in a physician’s office) are covered 

under this program. In order to collect the rebates, States must 

identify the drugs by their national drug codes and provide 

units-paid data to the drug company. Unlike self-administered 

drugs, which are typically billed to the State with national drug 

codes, physician-administered drugs are more often billed with 

procedure codes. States that use procedure codes to bill 

physician-administered drugs need a crosswalk to national drug 

codes in order to collect rebates on these drugs. A crosswalk is 

the identification of national drug codes for drugs represented 

by procedure codes. 

We asked Medicaid directors from 48 States and the District of 

Columbia about their coding and rebate policies concerning 

physician-administered drugs. We also requested financial 

data, such as total payments and units paid for physicianadministered drugs in calendar year 2001. Arizona and 

Tennessee did not participate in the rebate program that year. 

We estimated potential savings on all the single-source and 40 

OEI - 03 - 02 - 00660 MEDICAID REBATES FOR P HYSICIAN - A DMINISTERED D RUGS ii 
EXECUTIVE SUMMARY 

multiple-source, physician-administered drugs for which States 

made payments but did not receive rebates in 2001. 

FINDINGS 

In 2001, 17 States collected rebates for physicianadministered drugs, and 31 States did not. Of the 17 

States that collected drug manufacturer rebates for physicianadministered drugs in 2001, 3 collected rebates on all physicianadministered drugs. These three States use national drug codes 

for billing. The remaining 14 States use procedure codes. These 

14 States crosswalk procedure codes to national drugs codes for 

single-source drugs and collect rebates on these drugs only. 

Thirty-one States did not collect rebates on any physicianadministered drugs in 2001, and 1 additional State did not 

respond to our question about rebate collection. 

Medicaid could have saved millions of additional rebate 

dollars on physician-administered drugs in 2001. If all 

States had collected rebates for all single-source and 40 

multiple-source, physician-administered drugs, Medicaid could 

have added $37 million to its rebate savings for 2001. The 

majority of additional savings ($30 million) would have been on 

rebates for single-source drugs alone, and the remainder 

($7 million) would have been on 40 multiple-source drugs. 

After 2001, 7 of 31 States that had not collected rebates on 

physician-administered drugs began to do so. Of the 7 States 

that began collecting rebates after 2001, 6 States collect rebates on 

single-source, physician-administered drugs, and 1 State collects 

rebates on all physician-administered drugs billed by a targeted 

group of providers. (We estimated that the 2001 potential savings for 

these seven States was $14 million on all single-source and 40 

multiple-source physician administered drugs.) As of March 2003, 24 

States still did not collect rebates on any physician-administered 

drugs. These 24 States spent a total of $125 million on physicianadministered drugs. Five of these 24 States said they have no plans 

to collect rebates for physician-administered drugs. While 19 of 

these 24 States said they plan to collect rebates for these drugs, 13 of 

the 19 States did not have specific plans to collect rebates. 

OEI - 03 - 02 - 00660 MEDICAID REBATES FOR P HYSICIAN - A DMINISTERED D RUGS iii 
EXECUTIVE SUMMARY EXECUTIVE SUMMARY 

For States that had data available, rebates either 

requested or collected in 2001 exceeded the system 

implementation cost of collecting rebates for physicianadministered drugs. Four States provided us with their 

estimated costs for implementing system changes to collect 

rebates for physician-administered drugs. For each of these 

States, rebates in 2001 alone exceeded their one-time 

implementation costs. The State that spent the most ($642,000) 

collected $3 million in rebates for all physician-administered 

drugs in 2001. The State that spent the least ($56,100) collected 

$3 million in rebates on single-source, physician-administered 

drugs in 2001. 

RECOMMENDATION 

Rebates for physician-administered drugs help States reduce 

prescription drug expenditures, which are rising at a time when 

State budgets are severely stressed. Federal and State Medicaid 

expenditures on physician-administered drugs could have been 

reduced by an estimated $37 million in 2001 if all States 

collected rebates on those drugs. 

Based on cost estimates provided to us from States that have 

implemented changes in order to collect rebates for physicianadministered drugs, the savings from rebates in 1 year can 

exceed the one-time costs of implementing system changes. 

We recommend that CMS continue to encourage all States to 

collect rebates on physician-administered drugs, especially 

single-source drugs. As part of this effort, CMS should 

encourage cooperation and the sharing of information between 

States that collect rebates for these drugs, and States that do 

not, in order to facilitate rebate collection. It would be valuable 

for States that do not collect rebates for physician-administered 

drugs to know the details of implementing system changes, such 

as the what, where, when, and why of resources needed, and 

how the process unfolded for States that have been down this 

road. CMS could also issue a letter to State Medicaid Directors 

informing them about the availability and usefulness of the 

Medicare crosswalk. States could use this crosswalk, which is 

on the Internet, to reduce the administrative costs of creating 

and/or updating their own crosswalk. 

OEI - 03 - 02 - 00660 MEDICAID REBATES FOR P HYSICIAN - A DMINISTERED D RUGS iv 
EXECUTIVE SUMMARY 

AGENCY COMMENTS 

CMS concurred with our recommendation and is currently 

facilitating information sharing. The agency is passing on 

information to States seeking help to collect rebates on 

physician-administered drugs and providing contact names in 

States that have experience in this area. In addition, CMS has 

asked its Pharmacy Technical Advisory Group to serve as a 

resource to share this information with States in their consortia. 

CMS disagreed with our $37 million estimate of potential 

savings. As we reported, States provided us their payment and 

rebate information for physician-administered drugs for 

calendar year 2001 and told us whether they collected rebates 

on physician-administered drugs that year. We used the 

information provided by the States to calculate additional 

potential savings for each State in 2001. We acknowledge that 

the savings in future years will depend on rebate amounts and 

utilization and would likely be different from 2001. 

CMS also commented that our report did not break out the 

States that did not collect rebates in 2001 and that our report 

did not estimate their potential savings. We wish to point out 

that in Table 1 in Appendix A, we showed which States did not 

collect rebates in 2001 and which States told us they began 

collecting rebates after 2001. We also showed the 2001 potential 

savings for each State in Table 3 of Appendix A. We have added 

two sentences to page 10, citing the 2001 potential savings for 

seven States that began collecting rebates after 2001. 

CMS noted that of the 24 States not collecting rebates as of 

March 2003, 13 States had specific plans to collect rebates for 

these drugs and 6 States, while not having plans in place, 

indicated they will collect these rebates in the future. Our 

study, however, found the opposite for this subset of States. 

Thirteen States did not have specific plans, and six States did 

have specific plans (pages 10-11). In Appendix A, Table 1, we 

have added footnotes 12, 13, and 14 to identify the States that 

said they do not have specific plans, do have specific plans, and 

do not plan to collect rebates for these drugs. The full text of 

CMS comments is in Appendix B. 

OEI - 03 - 02 - 00660 MEDICAID REBATES FOR P HYSICIAN - A DMINISTERED D RUGS v 
TABLE OF CONTENTS

ABSTRACT ................................ ....................... i

EXECUTIVE SUMMARY ................................ ........ i i

INTRODUCTION ................................ .................. 1

FINDINGS ................................ ........................ 9

States that collected, or did not collect, rebates on physicianadministered drugs in 2001 ................................................................9

Medicaid could have saved millions in 2001.......................................9

States that began collecting rebates after 2001................................ 10

Implementation costs can be recovered quickly ............................. 11

RECOMMENDATION ................................ ............ 13

APPENDIX~A ................................ .................... 15

Table 1. Summary of 2001 State Medicaid Data for

Physician-Administered Drugs......................................................... 15

Table 2. Selected Physician-Administered Multiple-Source 

Drugs (n=40) ..................................................................................... 17

Table 3. Potential Medicaid Savings on Rebates for 

Physician-Administered Drugs in 2001............................................ 18

APPENDIX~B ................................ .................... 19

Agency Comments............................................................................. 19

ACKNOWLEDGMENTS ........................................................................ 21

OEI - 03 - 02 - 00660 MEDICAID REBATES FOR P HYSICIAN - A DMINISTERED D RUGS vi
INTRODUCTION

OBJECTIVES 

(1) To determine whether all State Medicaid agencies collect 

drug manufacturer rebates for all physician-administered drugs. 

(2) To estimate the potential savings that would result if all 

State Medicaid agencies collected drug manufacturer rebates for 

physician-administered drugs. 

BACKGROUND 

The Medicaid program, established under Title XIX of the Social 

Security Act, is administered by States and financed with State 

and Federal funds. Medicaid pays for medical and healthrelated assistance for certain vulnerable and needy individuals 

and families. All 50 States and the District of Columbia provide 

coverage for prescription drugs under the Medicaid program. 

From 1997 to 2000, Medicaid spending for outpatient 

prescription drugs grew twice as fast as total Medicaid 

spending. The total payments for outpatient prescription drugs 

in fiscal year 2000 were $21 billion. 

Drug Manufacturer Rebates 

In fiscal year 2000, drug manufacturers paid the Medicaid 

program $4 billion in rebates. This reduced Medicaid drug 

expenditures by 19 percent (total payments before rebates, 

$21 billion; after rebates, $17 billion). 

State Medicaid agencies receive manufacturer rebates for drugs 

under the Medicaid Drug Rebate Program. This program was 

established by Federal law in 1990 (see section 1927 of the 

Social Security Act). States cover all prescription drugs 

produced by manufacturers who have entered into rebate 

agreements under this program. Physician-administered drugs 

(drugs that a medical professional administers to a patient in a 

physician’s office) are among the drugs covered by the rebate 

program. Only two States, Arizona and Tennessee, did not 

participate in the rebate program at the time of our review. 

Under the rebate program, manufacturers are required to 

provide a rebate on drugs paid for by a State Medicaid agency. 

In order to collect a rebate, the State is required to identify the 

drugs by their national drug codes and provide quarterly unitsOEI - 03 - 02 - 00660 MEDICAID REBATES FOR P HYSICIAN - A DMINISTERED D RUGS 1 
INTRODUCTION 

paid data to the manufacturer. The manufacturer then pays the 

State a rebate, based on the unit rebate amount per drug 

multiplied by the number of drug units for which the State made 

payments. 

Codes Used to Bill Physician-Administered Drugs 

Self-administered drugs are typically billed by pharmacies in 

pharmacy claim formats using national drug codes to identify 

specific drug products. Physician-administered drugs, on the 

other hand, are more often billed by medical providers on 

professional service claims. (An example of a physicianadministered drug is a prescription drug given by injection in a 

doctor’s office.) Professional service claims identify services, 

medical equipment, and physician-administered drugs by 

procedure codes (i.e., the Healthcare Common Procedure Codes). 

While it is possible to use either a national drug code or a 

procedure code to bill for a physician-administered drug, these 

codes identify different things. The national drug code is an 

11-digit numeric code, which is divided into 3 segments 

identifying (1) the firm that manufactures, distributes, or 

repacks the drug product; (2) the specific strength, dosage form, 

and formulation of the product for a particular firm; and (3) the 

product’s package size. The procedure code is a 5-digit alphanumeric code that identifies a drug by its generic name; route of 

administration (e.g., oral or injection); and identifies the number 

of drug units allowed per reimbursement amount for that code. 

As mentioned above, States must identify drugs by their 

national drug code in order to collect rebates. Therefore, if a 

State requires the use of national drug codes for physicianadministered drugs, identifying the drug by its national drug 

code for rebate collection is not a problem. If a State requires 

the use of procedure codes for physician-administered drugs, 

identifying the drug by its drug code can be difficult. For 

example, if the drug reimbursed by Medicaid has more than one 

manufacturer, the drug would have more than one national drug 

code. Therefore, the State would not be able to determine which 

national drug code matched the procedure code. 

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INTRODUCTION 

Past OIG Work Found that Few States Collected Rebates for 

Physician-Administered Drugs 

In 1996, the Office of Inspector General (OIG) conducted the 

study, Appropriateness of Medicare Prescription Drug 

Allowances, (OEI-03-95-00420). It examined Medicare 

allowances for prescription drugs through a comparison with 

Medicaid reimbursement mechanisms and Medicaid drug 

rebates. During the study, OIG found that while most State 

Medicaid agencies participated in the rebate program, only six 

were collecting rebates on physician-administered drugs. 

States’ ability to collect rebates for physician-administered 

drugs was contingent upon their ability to identify the drugs by 

their national drug codes. 

Federal Effort to Encourage States to Collect Rebates for PhysicianAdministered Drugs 

In 2002, the Centers for Medicare & Medicaid Services (CMS) 

informally gathered information regarding State collection of 

rebates for physician-administered drugs. This was done 

through the Pharmacy Technical Advisory Group ? a group 

composed of CMS and State representatives. From this data 

collection, it appeared to CMS that States could gain 

considerable savings if they collected rebates on these drugs. 

CMS wrote to State Medicaid Directors in March 2003, 

encouraging them to look into system conversions that would 

facilitate a crosswalk of procedure codes to national drug codes 

and make rebate collection possible for these drugs. A crosswalk 

is the identification of national drug codes for drugs represented 

by procedure codes. 

Availability of Medicare Crosswalk 

States that use procedure codes for physician-administered 

drugs need a crosswalk to national drug codes in order to collect 

rebates on these drugs. A Medicare crosswalk is available on 

the Internet. It contains drugs paid by Medicare in a particular 

quarter and it is updated quarterly. The Internet address is: 

http://www.cms.hhs.gov/providers/drugs/backgroundsdp.asp. 

OEI - 03 - 02 - 00660 MEDICAID REBATES FOR P HYSICIAN - A DMINISTERED D RUGS 3 
INTRODUCTION INTRODUCTION 

METHODOLOGY 

Preliminary Research 

We conducted background research on the Medicaid Drug 

Rebate Program and code requirements for drug claims, 

including a review of Federal laws, regulations, manuals, and 

program memoranda. We reviewed Medicaid expenditures for 

prescription drugs, and we also reviewed public and private 

studies addressing the Medicaid prescription drug program and 

cost controls. 

State Medicaid Data 

In January 2003, we began collecting a formal set of data from 

the 49 States (i.e., 48 States and the District of Columbia) that 

participate in the Medicaid Drug Rebate Program. For the sake 

of brevity, we use the word “State” in this report as a synonym 

for both “State Medicaid agency” and “State Medicaid agency 

representative.” We refer to the District of Columbia as a State 

for the same reason. We sent our data request to State 

Medicaid directors. 

We asked each State whether they collect rebates for physicianadministered drugs, the year they began collecting rebates and 

for what types of drugs, the type of code they use to bill 

physician-administered drugs, the types of changes they made 

to their systems in order to collect rebates for physicianadministered drugs, and the estimated costs of changing 

systems for this purpose. We also asked each State to provide 

us a set of financial data for physician-administered drugs in 

calendar year 2001, namely, total payments per code, total units 

paid per code, rebate dollars requested of manufacturers per 

code, and rebate dollars received from manufacturers per code. 

Forty-eight States answered the questions we sent them, and 

most States provided all or some of the financial data we 

requested. The State of Nevada provided financial data but did 

not respond to the questions. We did not verify the data States 

sent us. Table 1 in the Appendix includes the State financial 

data. 

CMS Data 

We used CMS’s 2001 list of national Healthcare Common 

Procedure Codes with complete definitions to identify the 

OEI - 03 - 02 - 00660 MEDICAID REBATES FOR P HYSICIAN - A DMINISTERED D RUGS 4 
INTRODUCTION 

universe of codes that represented physician-administered 

drugs. 

We used calendar year 2001 data from CMS’s Medicaid 

Statistical Information System (MSIS) to identify payments and 

units paid per code for physician-administered drugs for States 

that did not send us this information (see Table 1 in Appendix 

A). Five States did not provide payment and unit data, and an 

additional two States did not provide unit data. We aggregated 

the State payment data received directly from States with data 

retrieved from MSIS to determine total Medicaid payments and 

utilization for physician-administered drugs. 

CMS’s Medicaid Drug Rebate Initiative database (hereinafter 

called rebate database) was used to identify drug unit rebate 

amounts in calendar year 2001. Since unit rebate amounts are 

established quarterly, we took the unit rebate amount for each 

quarter and calculated the average. The average unit rebate 

amount was then used in our calculation to determine potential 

savings. 

We used the January 1, 2002 update of the Part B Drug 

Calculation File from CMS’s Single Drug Price contractor. The 

CMS contractor uses this file to establish a national Medicare 

payment allowance for procedure codes. The file is organized by 

procedure code. Data in this file for each of the 485 procedure 

codes for physician-administered drugs included the procedure 

code description and a list of associated drug products with their 

national drug codes. The CMS contractor used the 2001 Red 

Book, a national drug-pricing reference, to identify average 

wholesale prices for drugs in this file. 

We used the Part B Drug Calculation File to determine which 

procedure codes represented single-source drugs and which 

represented multiple-source drugs on the market in 2001. A 

single-source drug is a brand name drug that is manufactured 

under a patent and has no competing products. A multiplesource drug is a drug whose patent has expired and is 

manufactured by a number of different drug companies under 

different names. Multiple-source drugs may include generic 

drugs and brand name drugs. 

Single-source drugs are more likely to have only one national 

drug code and are more easily matched to a procedure code than 

OEI - 03 - 02 - 00660 MEDICAID REBATES FOR P HYSICIAN - A DMINISTERED D RUGS 5 
INTRODUCTION INTRODUCTION 

multiple-source drugs. If the Part B Drug Calculation File 

showed only one drug manufacturer for a procedure code, we 

took that to be an indication the procedure code represented a 

single-source drug. We then looked up that drug in the October 

2001 issue of Red Book TM for Windows® to confirm whether it 

was indeed a single-source drug. Drugs in the Part B Drug 

Calculation File that had multiple manufacturers or were not 

confirmed as single-source drugs in Red Book were put in the 

multiple-source drug category. 

We also used the Part B Drug Calculation File to identify the 

national drug codes for single-source and multiple-source drugs 

that corresponded to each procedure code. 

Analysis of Payments for Physician-Administered Drugs 

Using State financial data, we identified payments for singlesource and multiple-source, physician-administered drugs per 

State. Single-source drug payments for 46 States ranged from 

$43,000 to $20 million, for a national total of $148 million. 

Multiple-source drug payments for 46 States ranged from 

$12,000 to $18 million, for a national total of $152 million. 

Because California and Nevada use local codes (codes used by 

the individual States), and Massachusetts uses non-specific 

codes for physician-administered drugs, we did not identify 

payments for single-source and multiple-source drugs for these 

three States. We did, however, aggregate total payments for 

these three States with total payments for other States. Total 

national payments for physician-administered drugs in 2001 

were $364 million. A summary of payments is provided in 

Table 1 of Appendix A. 

Potential Savings Analysis 

Drugs Used to Calculate Savings. We reviewed all physicianadministered, single-source drugs and 40 multiple-source drugs 

for which States made payments in 2001 but did not request a 

rebate, and for which a unit rebate amount was available in the 

rebate database. The number of single-source drugs reimbursed 

by each State ranged from 17 to 149. Of the 40 multiple-source 

drugs reviewed, the number reimbursed by each State ranged 

from 5 to 39. We reviewed drugs billed with national procedure 

codes only. We did not review any drugs billed with local codes. 

Nor did we review vaccines or immunizations because these 

products are not covered under the rebate program. 

OEI - 03 - 02 - 00660 MEDICAID REBATES FOR P HYSICIAN - A DMINISTERED D RUGS 6 
INTRODUCTION 

We selected the 40 multiple-source drugs in the following way. 

We took the State-reported payment data for physicianadministered drugs billed with procedure codes and removed 

payments for codes that received rebates in 2001. We then 

aggregated the payments nationally by code. We arrayed the 

aggregated payments from high to low and selected 40 codes for 

multiple-source drugs having the highest payments. These 40 

drugs represented $71 million in total Medicaid payments. 

Table 2 in Appendix A lists the 40 drugs. 

In order to separate single-source drugs from multiple-source 

drugs, we matched the State’s procedure codes with procedure 

codes in our crosswalk of single-source drugs. If the procedure 

code paid by the State did not match a procedure code in the 

single-source crosswalk, we included it in the multiple-source 

category. 

For States that collected rebates on single-source, physicianadministered drugs, we removed those codes from our analysis 

of the State’s potential savings. 

Identifying Unit Rebate Amounts. Unit rebate amounts for drugs 

are stored in the rebate database under the national drug code. 

Having completed a crosswalk for single-source drugs and 

selected multiple-source drugs, we compiled a list of national 

drug codes for the drugs under review in the single-source and 

multiple-source categories. We then obtained the unit rebate 

amount from the rebate database for each national drug code 

and calculated the average of the unit rebate amount for all 

quarters in 2001 for each national drug code. When more than 

one drug product was on the market for a particular procedure 

code, and therefore, had more than one national drug code and 

unit rebate amount in the rebate database, we identified the 

median unit rebate amount. 

In instances where the strength of the national drug code did 

not exactly match the strength of the procedure code, we applied 

a conversion factor to calculate the correct unit rebate amount 

for the procedure code. The unit rebate amount per procedure 

code was then used to calculate potential savings for each 

procedure code in each State. 

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INTRODUCTION 

Potential Savings Calculation. We used the following steps to 

determine potential savings: 

Step 1. For each procedure code, we multiplied the total 

number of drug units paid for the procedure code in 2001 

by the unit rebate amount per procedure code. The 

product of this calculation was the potential savings for 

the procedure code. 

Step 2. We calculated each State’s total potential 

savings by adding the potential savings for each 

procedure code. 

Step 3. In order to determine total Medicaid potential 

savings, we summed the potential savings from each of 

the States. 

We noticed that in Step 1, savings for some procedure codes 

exceeded payments. This might have been the result of a State’s 

units-paid data not accurately representing paid claim units. In 

any State where potential savings for a procedure code exceeded 

the payments for that code, we removed the code from our 

savings calculations. 

Reporting the Potential Savings. Table 3 in Appendix A contains 

potential Federal and State savings per State. These savings 

were calculated on physician-administered drug payments of 

$169 million. This was the subset of payments for single-source 

and 40 multiple-source drugs for which the States did not 

request rebates in 2001. In addition, these payments do not 

include vaccines or immunizations, drugs billed with local codes 

or non-specific codes, and codes deleted because savings 

calculations exceeded payments. 

____________________________ 

This study was conducted in accordance with the Quality 

Standards for Inspections issued by the President’s Council on 

Integrity and Efficiency. 

OEI - 03 - 02 - 00660 MEDICAID REBATES FOR P HYSICIAN - A DMINISTERED D RUGS 8 
� FINDINGS

Of the 17 States that collected In 2001, 17 States collected rebates on drug manufacturer rebates on physician-administered drugs, and 31 States physician-administered drugs in 

did not. 2001, 3 States collected rebates 

on all such drugs, and 14 collected rebates on single-source 

drugs only. 

Three States that use national drug codes for billing were able to 

collect rebates on all physician-administered drugs. 

Only three States use national drug codes to bill physicianadministered drugs (Hawaii, Missouri, and Pennsylvania). They 

were able to collect rebates for physician-administered drugs 

regardless of whether the drugs were single-source or multiplesource. Two of the three States sent us their data on total 

rebates collected in 2001. These two States collected $3 million 

in rebates or 30 percent of their total payments ($10 million) for 

physician-administered drugs. 

Fourteen States were only able to collect rebates on single-source, 

physician-administered drugs. 

Fourteen States that use procedure codes instead of national 

drug codes to bill physician-administered drugs were able to 

collect rebates for single-source drugs only. The four States that 

provided data collected $14 million in rebates on these drugs. 

In order to collect rebates for single-source drugs, these 

14 States developed a crosswalk to link procedure codes to 

national drug codes; developed conversion factors for codes 

where the description of procedure code units differed from 

rebate units; performed regularly scheduled system 

maintenance (e.g., to verify that the drug code is still active); 

identified claims with procedure codes that were, or could be, 

crosswalked; and changed the rebate invoicing procedure to 

merge physician services and pharmacy claims. 

Medicaid could have saved millions of additional Medicaid could have added an 

rebate dollars on physician-administered drugs estimated $37 million to its 

in 2001. rebate savings in 2001 if all 

States had collected rebates on 

single-source and 40 multiple-source, physician-administered 

drugs. Individual State payments and potential savings are in 

Tables 1 and 3 of Appendix A. 

OEI - 03 - 02 - 00660 MEDICAID REBATES FOR P HYSICIAN - A DMINISTERED D RUGS 9 
FINDINGS FINDINGS 

Medicaid would have obtained the majority of these rebate savings 

from single-source drugs. 

States that did not collect rebates for single-source, physicianadministered drugs had payments totaling $99 million for this 

subset of drugs. These States could have reduced 2001 

expenditures on these drugs by an estimated 30 percent or 

$30 million if rebates had been collected. 

Medicaid could have obtained further savings in rebates for 40 

multiple-source drugs. 

The States that did not collect rebates for 40 multiple-source, 

physician-administered drugs paid $70 million for these drugs 

in 2001. These States could have lowered payments by an 

estimated $7 million or 10 percent by collecting the rebates. 

After 2001, 7 of 31 States that 

After 2001, 7 of 31 States that had not collected had not collected rebates on any 

rebates on physician-administered drugs began physician-administered drugs 

to do so. began collecting rebates for some 

of these drugs. Six of these seven 

States implemented changes (e.g., developed a crosswalk) to 

collect rebates for single-source, physician-administered drugs. 

The remaining State reported that it targets the eight highest 

paid providers who bill physician-administered drugs and asks 

them to provide the national drug code from the product 

dispensed for the paid claim. Once the State has the drug code, 

rebate invoices can be sent to manufacturers. 

The 2001 potential savings for these 7 States was $14 million on 

all single-source and 40 multiple-source, physician-administered 

drugs. This $14 million represents 38 percent of the total $37 

million in potential savings for 2001. 

As of March 2003, 24 States still did not collect rebates on any 

physician-administered drugs. 

The 24 States that did not collect rebates on physicianadministered drugs as of March 2003, reported spending $125 

million for these drugs in 2001. Nineteen of these 24 States said 

they plan to collect rebates for physician-administered drugs. 

However, 13 of 19 have no specific plans to change their 

systems. Some of these 13 States said that they were aware of 

changes that are needed, and others said they did not know 

what changes are needed. Four of the 19 States indicated they 

have begun the process of making changes to their systems, 

OEI - 03 - 02 - 00660 MEDICAID REBATES FOR P HYSICIAN - A DMINISTERED D RUGS 10 
FINDINGS 

such as ordering a change to their Medicaid Management 

Information System, developing a crosswalk, building a new 

claims management system to accommodate national drug codes 

on professional service claims, and changing policies and billing 

instructions to require national drug codes. The remaining 2 of 

19 States responded that they have created crosswalks for 

single-source drugs. 

Five of 24 States that currently do not collect rebates on 

physician-administered drugs said they do not have plans to 

collect rebates for these drugs. These 5 States had $25 million 

in expenditures for physician-administered drugs. 

For States that had data available, rebates Of the States currently 

requested or collected in 2001 exceeded the collecting rebates on 

physician-administered system implementation cost of collecting rebates drugs, four were able to

for physician-administered drugs. provide system 

implementation costs for collecting rebates for these drugs. 

Costs ranged from a high of $642,000 to a low of $56,100. 

• The State that reported the highest implementation cost 

estimate ($642,000) is a State that now collects rebates 

for all physician-administered drugs. This State 

implemented a policy change in 1992 that required 

physician-administered drugs be billed on pharmacy 

claims forms. Then, in 1994, they spent an estimated 

$642,000 to integrate the pharmacy rebate system into 

their Medicaid Management Information System. In 

2001, they collected $3 million in rebates for physicianadministered drugs. 

• A State that began collecting rebates in 2001 for singlesource, physician-administered drugs spent an estimated 

$220,000. They made modifications to their Medicaid 

Management Information System, including creating a 

crosswalk and tables to store physician-administered 

drug claims, and merging physician services and 

pharmacy claims for rebate invoicing. In 2001, this 

State requested $2 million in rebates from drug 

manufacturers for single-source, physician-administered 

drugs. 

OEI - 03 - 02 - 00660 MEDICAID REBATES FOR P HYSICIAN - A DMINISTERED D RUGS 11 
FINDINGS 

• Another State estimated spending $110,000 for 

personnel needed to make system changes to collect 

rebates for single-source, physician-administered drugs. 

This State began collecting rebates for these drugs after 

2001, but in 2001 the State invoiced manufacturers 

$1 million for rebates on these drugs. 

• The State that had the lowest implementation costs 

($56,100) collected $3 million for single-source, 

physician-administered drugs in 2001. This State began 

collecting the rebates in 1998. This State’s 

implementation costs were for a system engineer to 

create a link between procedure codes and national drug 

codes, add programming that automatically relates 

procedure-code billing to drug-code billing, merge 

physician and pharmacy claims for invoicing, and test 

the system. 

Three additional States said they plan to collect rebates for 

single-source, physician-administered drugs. These States 

estimated the costs for system changes would range from 

$10,008 to $150,000. In addition to these one-time 

expenditures, 1 State planning to make changes said it would 

cost approximately $1,500 per year to maintain the new system. 

OEI - 03 - 02 - 00660 MEDICAID REBATES FOR P HYSICIAN - A DMINISTERED D RUGS 12 
RECOMMENDATION

RECOMMENDATION 

Rebates for physician-administered drugs help States reduce 

prescription drug expenditures, which are rising at a time when 

State budgets are severely stressed. Federal and State Medicaid 

expenditures on physician-administered drugs could have been 

reduced by an estimated $37 million in 2001 if all States 

collected rebates on those drugs. 

Based on cost estimates provided to us from States that have 

implemented changes in order to collect rebates for physicianadministered drugs, the savings from rebates in 1 year can 

exceed the one-time costs of implementing system changes. 

We recommend that CMS continue to encourage all States to 

collect rebates on physician-administered drugs, especially 

single-source drugs. As part of this effort, CMS should 

encourage cooperation and the sharing of information between 

States that collect rebates for these drugs and States that do 

not, in order to facilitate rebate collection. It would be valuable 

for States that do not collect rebates for physician-administered 

drugs to know the details of implementing system changes, such 

as the what, where, when, and why of resources needed, and 

how the process unfolded for States that have been down this 

road. CMS could also issue a letter to State Medicaid Directors 

informing them about the availability and usefulness of the 

Medicare crosswalk. States could use this crosswalk, which is 

on the Internet, to reduce the administrative costs of creating 

and/or updating their own crosswalk. 

AGENCY COMMENTS 

CMS concurred with our recommendation and is currently 

facilitating information sharing. The agency is passing on 

information to States seeking help to collect rebates on 

physician-administered drugs and providing contact names in 

States that have experience in this area. In addition, CMS has 

asked its Pharmacy Technical Advisory Group to serve as a 

resource to share this information with States in their consortia. 

CMS disagreed with our $37 million estimate of potential 

savings. As we reported, States provided us their payment and 

OEI - 03 - 02 - 00660 MEDICAID REBATES FOR P HYSICIAN - A DMINISTERED D RUGS 13 
RECOMMENDATION 

rebate information for physician-administered drugs for 

calendar year 2001 and told us whether they collected rebates 

on physician-administered drugs that year. We used the 

information provided by the States to calculate additional 

potential savings for each State in 2001. We acknowledge that 

the savings in future years will depend on rebate amounts and 

utilization and would likely be different from 2001. 

CMS also commented that our report did not break out the 

States that did not collect rebates in 2001 and that our report 

did not estimate their potential savings. We wish to point out 

that in Table 1 in Appendix A, we showed which States did not 

collect rebates in 2001 and which States told us they began 

collecting rebates after 2001. We also showed the 2001 potential 

savings for each State in Table 3 of Appendix A. We have added 

a sentence to page 10, citing the 2001 potential savings for seven 

States that began collecting rebates after 2001. 

CMS noted that of the 24 States not collecting rebates as of 

March 2003, 13 States had specific plans to collect rebates for 

these drugs and 6 States, while not having plans in place, 

indicated they will collect these rebates in the future. Our 

study, however, found the opposite for this subset of States. 

Thirteen States did not have specific plans, and six States did 

have specific plans (pages 10-11). In Appendix A, Table 1, we 

have added footnotes 12, 13, and 14 to identify the States that 

said they do not have specific plans, do have specific plans, and 

do not plan to collect rebates for these drugs. The full text of 

CMS comments is in Appendix B. 

OEI - 03 - 02 - 00660 MEDICAID REBATES FOR P HYSICIAN - A DMINISTERED D RUGS 14 
APPENDIX~A

Table 1. Summary of 2001 State Medicaid Data for Physician-Administered Drugs 

This table incorporates the States’ responses to our information request. From January 

through March 2003, we collected a formal set of data from the 49 States (i.e., 48 States and 

the District of Columbia) that participate in the Medicaid Drug Rebate Program. We 

specifically asked States to provide us with financial data for physician-administered drugs 

only, and not to include crossover drug claims from Medicare. A number of States included 

vaccines and immunizations in the financial data they sent us. However, these products are 

not covered under the Medicaid Drug Rebate Program. Therefore, we excluded vaccine and 

immunization data from our analysis of payments and potential savings and from this table. 

State 

Physician-Administered 

Drug Payments in 2001 

Physician-Administered 

Drugs for which States 

Collected Rebates in 2001 

Rebates Requested 

of Drug 

Manufacturers for 

PhysicianAdministered Drugs in 

2001 

Rebates Collected 

from Drug 

Manufacturers for 

PhysicianAdministered Drugs in 

2001 

Alabama $13,196,168 8 None1 

Alaska $2,229,910 None13 

Arkansas $4,159,582 None13 

California6 $59,278,322 Single-Source $6,417,891 $5,445,273 

Colorado $3,211,272 3 None14 

Connecticut $3,776,003 8 Single-Source Not Available Not Available 

Delaware $55,008 Single-Source Not Available Not Available 

District of Columbia $995,166 None12 

Florida $22,037,705 None1 

Georgia $13,205,614 4 Single-Source $2,465,042 4 $3,627,956 4 

Hawaii $479,692 All $237,295 $135,872 

Idaho $1,830,202 None12 

Illinois9 $1,612,548 None12 

Indiana $9,806,848 Single-Source $2,280,000 3 Not Available 

Iowa $5,407,563 8 None14 

Kansas $4,170,742 8 Single-Source Not Available Not Available 

Kentucky $1,995,578 None1 

Louisiana $3,723,133 None1 

Maine $1,840,082 None12 

Maryland $25,235,109 None1 

Massachusetts 6 $190,676 None13 

Michigan $6,625,762 7 Single-Source $1,964,919 7 $1,193,894 7 

Minnesota $5,451,191 None13 

Mississippi $5,606,025 None12 

Missouri $9,979,292 All $2,887,966 $2,875,550 

Montana $1,896,598 3 None12 

Nebraska9 $3,174,260 5 None12 

Nevada $4,510,532 Not Available10 

New Hampshire $621,931 Single-Source $78,914 Not Available 

New Jersey $2,274,470 None14 

New Mexico $563,289 None12 

New York $23,301,898 None12 

North Carolina $14,817,041 Single-Source $3,522,962 $3,285,105 

OEI - 03 - 02 - 00660 MEDICAID REBATES FOR P HYSICIAN - A DMINISTERED D RUGS 15 
1 

2

3

4

5

6

7

8 

9

APPENDIX~A 

North Dakota $367,185 None12 

Ohio $13,344,648 None14 

Oklahoma $3,880,609 None12 

Oregon $8,569,989 Single-Source $1,437,366 Not Available 

Pennsylvania $772,931 All Not Available Not Available 

Rhode Island $527,412 8 Single-Source Not Available Not Available 

South Carolina $10,277,645 Single-Source Not Available Not Available 

South Dakota $591,771 None13 

Texas $35,534,137 None13 

Utah $1,095,075 None12 

Vermont $1,247,256 None1 

Virginia $2,597,819 Single-Source $612,957 Not Available 

Washington $17,740,284 None2 

West Virginia $6,529,169 3 None12 

Wisconsin $3,548,728 Single-Source $634,259 Not Available 

Wyoming $269,851 None14 

4911 $364,153,722 $22,539,571 $16,563,651 

Sources: State Medicaid agency data provided to OIG January -March 2003, and CMS’s Medicaid Statistical Information System 

After 2001, State began to collect rebates on single-source drugs. 

After 2001, State began collecting rebates for drugs billed by the 8 highest paid providers. 

Fiscal year data. 

Eleven months of data. 

Based on service (not payment) dates. 

This State’s data is represented entirely by local codes or non-specific codes. 

Includes crossover drug claims from Medicare. 

State did not provide financial data to us. Therefore, we used data from CMS’s Medicaid Statistical Information System. 

State provided us with payments but not units. Therefore, we used units from CMS’s Medicaid Statistical Information System to calculate potential 

savings. Potential savings are in Table 3.

10 State provided us with financial data but did not respond to the questions.

11 Arizona and Tennessee did not participate in the Medicaid Drug Rebate Program at the time of our study.

12 State said it planned to collect rebates for physician-administered drugs in the future, but the plans were not specific.

13 State said it had specific plans underway to collect rebates for physician-administered drugs.

14 State did not plan to collect rebates for physician-administered drugs.

OEI - 03 - 02 - 00660 MEDICAID REBATES FOR P HYSICIAN - A DMINISTERED D RUGS 16 
APPENDIX~A 

Table 2. Selected Physician-Administered Multiple-Source Drugs (n=40) 

Procedure Code Description 

J0640 INJECTION, LEUCOVORIN CALCIUM, PER 50 MG 

J1040 INJECTION, METHYLPREDNISOLONE ACETATE, 80 MG 

J1100 INJECTION, DEXAMETHASONE SODIUM PHOSPHATE, 1MG 

J1245 INJECTION, DIPYRIDAMOLE, PER 10 MG 

J1561 INJECTION, IMMUNE GLOBULIN, INTRAVENOUS, 500 MG 

J1562 INJECTION, IMMUNE GLOBULIN, INTRAVENOUS, 5 GMS 

J1563 INJECTION, IMMUNE GLOBULIN, INTRAVENOUS, 1G 

J1631 INJECTION, HALOPERIDOL DECANOATE, PER 50 MG 

J1642 INJECTION, HEPARIN SODIUM, (HEPARIN LOCK FLUSH), PER 10 UNITS 

J1644 INJECTION, HEPARIN SODIUM, PER 1000 UNITS 

J1750 INJECTION, IRON DEXTRAN, 50 MG 

J1885 INJECTION, KETOROLAC TROMETHAMINE, PER 15 MG 

J2000 INJECTION, LIDOCAINE HCL, 50 CC 

J2275 INJECTION, MORPHINE SULFATE (PRESERVATIVE-FREE STERILE SOLUTION), PER 10 MG 

J2550 INJECTION, PROMETHAZINE HCL, UP TO 50 MG 

J2680 INJECTION, FLUPHENAZINE DECANOATE, UP TO 25 MG 

J2912 INJECTION, SODIUM CHLORIDE, 0.9%, PER 2 ML 

J3370 INJECTION, VANCOMYCIN HCL, 500 MG 

J7050 INFUSION, NORMAL SALINE SOLUTION, 250 CC 

J7190 FACTOR VIII (ANTIHEMOPHILIC FACTOR, HUMAN) PER I.U. 

J7192 FACTOR VIII (ANTIHEMOPHILIC FACTOR, RECOMBINANT) PER I.U. 

J7194 FACTOR IX, COMPLEX, PER I.U. 

J7619 

ALBUTEROL, ALL FORMULATIONS INCLUDING SEPARATED ISOMERS, INHALATION 

SOLUTION ADMINISTERED THROUGH DME, UNIT DOSE FORM, PER 1 MG 

J9000 DOXORUBICIN HCL, 10 MG 

J9040 BLEOMYCIN SULFATE, 15 UNITS 

J9060 CISPLATIN, POWDER OR SOLUTION, PER 10 MG 

J9062 CISPLATIN, 50 MG 

J9181 ETOPOSIDE, 10 MG 

J9182 ETOPOSIDE, 100 MG 

J9190 FLUOROURACIL, 500 MG 

J9209 MESNA, 200 MG 

J9265 PACLITAXEL, 30 MG 

J9370 VINCRISTINE SULFATE, 1 MG 

Q0136 INJECTION, EPOETIN ALPHA, (FOR NON ESRD USE), PER 1000 UNITS 

Q9930 INJECTION OF EPO, PER 1000 UNITS, AT PATIENT HCT OF 30 

Q9932 INJECTION OF EPO, PER 1000 UNITS, AT PATIENT HCT OF 32 

Q9933 INJECTION OF EPO, PER 1000 UNITS, AT PATIENT HCT OF 33 

Q9934 INJECTION OF EPO, PER 1000 UNITS, AT PATIENT HCT OF 34 

Q9935 INJECTION OF EPO, PER 1000 UNITS, AT PATIENT HCT OF 35 

Q9936 INJECTION OF EPO, PER 1000 UNITS, AT PATIENT HCT OF 36 

Source: CMS’s 2001 list of Healthcare Common Procedure Codes 

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APPENDIX~A 

Table 3. Potential Medicaid Savings on Rebates for Physician-Administered Drugs in 2001 

State 

Potential Savings for All 

Single-Source PhysicianAdministered Drugs 

Potential Savings for Selected 

Multiple-Source PhysicianAdministered Drugs (n=40) 

Number of Selected MultipleSource Drugs With State 

Payments in 2001 (n=40) 

Total Potential 

Savings4 

Florida1 $5,528,662 $1,391,713 27 $6,920,375 

Texas $5,322,837 $750,305 30 $6,073,142 

Washington1 $2,271,591 $259,842 20 $2,531,432 

Alabama1 $1,341,721 $978,014 38 $2,319,735 

Ohio $2,007,335 $271,809 28 $2,279,144 

New York $1,238,323 $347,384 30 $1,585,707 

Mississippi $1,412,029 $83,198 24 $1,495,227 

West Virginia $1,296,469 $197,225 29 $1,493,694 

Maryland1 $1,254,053 $140,015 29 $1,394,069 

Minnesota $936,016 $143,601 32 $1,079,617 

Iowa $823,714 $223,213 38 $1,046,927 

Arkansas $999,389 $71,679 23 $1,071,068 

Nebraska $832,833 $153,363 26 $986,195 

Oklahoma $797,371 $44,944 25 $842,315 

New Jersey $455,750 $44,965 30 $500,715 

Montana $433,828 $44,894 30 $478,722 

Kentucky1 $440,601 $30,568 10 $471,169 

Colorado $367,984 $45,422 28 $413,406 

Louisiana1 $241,741 $159,806 23 $401,547 

Alaska $359,894 $41,153 21 $401,047 

Idaho $243,772 $75,102 36 $318,874 

North Carolina2 $307,865 30 $307,865 

Vermont1 $275,045 $25,902 22 $300,947 

Maine $247,267 $25,778 27 $273,045 

Utah $211,677 $13,203 27 $224,880 

Indiana2 $210,665 32 $210,665 

Michigan2 $181,748 28 $181,748 

South Carolina2 $175,382 27 $175,382 

District of Columbia $127,635 $5,107 25 $132,742 

Connecticut2 $132,157 37 $132,157 

Kansas2 $112,065 31 $112,065 

South Dakota $102,510 $6,605 25 $109,115 

North Dakota $74,405 $2,897 15 $77,302 

Illinois $59,909 $4,954 30 $64,862 

Wyoming $37,194 $5,008 13 $42,202 

Wisconsin2 $42,289 26 $42,289 

Georgia2 $39,815 16 $39,815 

Rhode Island2 $19,063 22 $19,063 

Oregon2 $18,152 18 $18,152 

New Mexico $12,055 $1,598 22 $13,653 

Virginia2 $9,938 5 $9,938 

New Hampshire2 $6,042 18 $6,042 

Delaware2 $361 13 $361 

433 $29,753,610 $6,844,810 $36,598,420 

Sources: State Medicaid agency data provided to the OIG January -March 2003, CMS’s Medicaid Statistical Information System, Medicaid Drug Rebate 

Initiative database, and Single Drug Price contractor’s Part B Drug Calculation File 

1

These States began collecting rebates on physician-administered drugs after 2001. 2 These States collected rebates on single-source drugs in 2001. We did not estimate potential savings on single-source drugs if a State collected rebates on 

these drugs . California collects rebates for single-source drugs but is not in this table because they use local codes. 3

Arizona and Tennessee did not participate in the Medicaid Drug Rebate Program at the time of our study. California and Massachusetts are not in this table 

because they use local and non-specific codes,respectively. Hawaii, Missouri, and Pennsylvania are not in this table because they use national drug codes 

and collect rebates on all physician-administered drugs. Nevada is not in this table because they did not respond to our questions asking if they collect 

rebates for physician-administered drugs. 4

The sum of potential savings for single-source and multiple-source drugs may not exactly equal total potential savings due to rounding. 

OEI - 03 - 02 - 00660 MEDICAID REBATES FOR P HYSICIAN - A DMINISTERED D RUGS 18 
� APPENDIX ~ B

Agency Comments 

OEI - 03 - 02 - 00660 MEDICAID REBATES FOR P HYSICIAN - A DMINISTERED D RUGS 19
APPENDIX~B 

Agency Comments 

OEI - 03 - 02 - 00660 MEDICAID REBATES FOR P HYSICIAN - A DMINISTERED D RUGS 20
ACKNOWLEDGMENTS

This report was prepared under the direction of Robert A. Vito, 

Regional Inspector General for Evaluation and Inspections in 

the Philadelphia Regional Office, and Linda M. Ragone, Deputy 

Regional Inspector General. Other principal Office of 

Evaluation and Inspections staff who contributed include: 

Isabelle Buonocore, Team Leader

Edward Burley, Program Analyst

Cynthia R. Hansford, Program Assistant

Linda Frisch, Program Specialist

Tricia Davis, Director, Medicare and Medicaid Branch

Technical Assistance 

Linda Moscoe, Program Analyst

OEI - 03 - 02 - 00660 MEDICAID REBATES FOR P HYSICIAN - A DMINISTERED D RUGS 21