Page 2 – Kerry Weems 

We recommend that Congress and CMS consider the results of our review, including the data 

provided, in any deliberations regarding Medicare Part D reimbursement. 

In its written comments on our draft report, CMS concurred with our recommendation. 

Pursuant to the principles of the Freedom of Information Act, 5 U.S.C. § 552, as amended by 

Public Law 104-231, Office of Inspector General reports generally are made available to the 

public to the extent the information is not subject to exemptions in the Act (45 CFR part 5). 

Accordingly, within 10 business days after this report is issued, it will be posted on the Internet 

at http://oig.hhs.gov. 

Please send us your final management decision, including any action plan, as appropriate, within 

60 days. If you have any questions or comments about this report, please do not hesitate to call 

me, or your staff may contact George M. Reeb, Assistant Inspector General for the Centers for 

Medicare & Medicaid Audits, at (410) 786-7104 or through e-mail at George.Reeb@oig.hhs.gov. 

Please refer to report number A-06-07-00107 in all correspondence.

Attachment 

 
 Department of Health and Human Services

OFFICE OF 

INSPECTOR GENERAL 

 

Daniel R. Levinson 

Inspector General 

January 2008 

A-06-07-00107 

 

REVIEW OF THE RELATIONSHIP 

BETWEEN MEDICARE PART D 

PAYMENTS TO LOCAL, 

COMMUNITY PHARMACIES AND 

THE PHARMACIES’ DRUG 

ACQUISITION COSTS 
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 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. These assessments help reduce waste, abuse, and mismanagement and promote 

economy and efficiency throughout HHS. 

 

Office of Evaluation and Inspections

The Office of Evaluation and Inspections (OEI) conducts national evaluations to provide HHS, 

Congress, and the public with timely, useful, and reliable information on significant issues. 

Specifically, these evaluations focus on preventing fraud, waste, or abuse and promoting 

economy, efficiency, and effectiveness in departmental programs. To promote impact, the 

reports also present practical recommendations for improving program operations. 

Office of Investigations

The 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. 

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. OCIG imposes program exclusions and civil monetary penalties on 

health care providers and litigates those actions within HHS. OCIG also represents OIG in the 

global settlement of cases arising under the Civil False Claims Act, develops and monitors 

corporate integrity agreements, develops compliance program guidances, renders advisory 

opinions on OIG sanctions to the health care community, and issues fraud alerts and other 

industry guidance. 
I 

Notices 


-


THIS REPORT IS AVAILABLE TO THE PUBLIC 

at http://oig. hhs.gov 

In accordance with the principles of the Freedom of Information Act (5 U.S.C. 552, 

as amended by Public Law 104-231), Office of Inspector General, Office of Audit 

Services reports are made available to members of the public to the extent the 

information is not subject to exemptions in the act. (See 45 CFR part 5.) 

OAS FINDINGS AND OPINIONS 

The designation of financial or management practices as questionable or a 

recommendation for the disallowance of costs incurred or claimed, as well as other 

conclusions and recommendations in this report, represent the findings and opinions 

of the HHSIOIGIOAS. Authorized officials of the HHS divisions will make final 

determination on these matters. 

9 

2 

EXECUTIVE SUMMARY 

BACKGROUND 

Title I of the Medicare Prescription Drug, Improvement, and Modernization Act of 2003 

established the Medicare Part D prescription drug program. Under Part D, which began 

January 1, 2006, individuals entitled to benefits under Part A or enrolled in Part B may obtain 

drug coverage. 

The Centers for Medicare & Medicaid Services (CMS), which administers Medicare, contracts 

with Part D sponsors to offer prescription drug benefits to eligible individuals. Pharmacies 

contract with these sponsors to obtain Part D reimbursement for prescription drugs dispensed to 

individuals enrolled in Part D plans. The sponsors pay pharmacies a rate for ingredient costs 

(i.e., drug acquisition costs), usually a published average wholesale price of the drug minus some 

percentage, as well as a dispensing fee. 

In a letter dated June 6, 2006, 33 Senators requested that we analyze three issues related to local, 

community pharmacies’ participation in the Medicare Part D program: network adequacy, 

contracting, and reimbursement. This report, which addresses the reimbursement aspect of the 

request, is based on our reviews of Part D payments and drug acquisition costs at 100 statistically 

selected pharmacies in September 2006. 

OBJECTIVES 

Our objectives were to (1) analyze the relationship between Medicare Part D payments, 

excluding dispensing fees, to local, community pharmacies and the pharmacies’ drug acquisition 

costs and (2) estimate Part D dispensing fees and compare them with Medicaid dispensing fees. 

SUMMARY OF RESULTS 

Medicare Part D payments, excluding dispensing fees, to local, community pharmacies exceeded 

the pharmacies’ drug acquisition costs by an estimated 18.1 percent when our analysis included 

rebates that drug wholesalers paid to pharmacies. Excluding rebates, Part D payments exceeded 

drug acquisition costs by an estimated 17.3 percent. The estimated difference between Part D 

payments and drug acquisition costs was $9.13 per prescription including rebates and $8.78 

excluding rebates. Our analyses also found that, including rebates: 

• Payments to pharmacies that were members of group purchasing organizations exceeded 

drug acquisition costs by an estimated 18.3 percent, compared with 17.7 percent for 

nonmember pharmacies. Member pharmacies received rebates on more drugs that were 

common to both member and nonmember pharmacies than did nonmember pharmacies. 

• Payments to rural pharmacies exceeded drug acquisition costs by an estimated 

18.9 percent, compared with 17.3 percent for nonrural pharmacies. The percentage 

difference appears to be related to the mix of generic and brand-name drugs dispensed 

rather than a difference in Part D payment rates. Rural pharmacies filled more generic 

prescriptions than did nonrural pharmacies. The percentage difference between Part D 

i
payments and drug acquisition costs was significantly higher for generic drugs than for 

brand-name drugs. 

The estimated average Medicare Part D dispensing fee paid to local, community pharmacies was 

$2.27 per prescription, about $2 less than the average Medicaid dispensing fee.

RECOMMENDATION 

We recommend that Congress and CMS consider the results of our review, including the data 

provided, in any deliberations regarding Medicare Part D reimbursement. 

CENTERS FOR MEDICARE & MEDICAID SERVICES COMMENTS 

In its written comments on our draft report, CMS concurred with our recommendation. The full 

text of CMS’s comments is included as Appendix G. 

ii
TABLE OF CONTENTS 

 Page

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

BACKGROUND ....................................................................................................1 

Senate Request Letter .................................................................................1 

Medicare Part D Reimbursement of Drugs.................................................1 

National Council for Prescription Drug Programs Pharmacy Database.....2 

National Drug Codes...................................................................................2 

First DataBank, Inc., Drug Database ..........................................................2 

 OBJECTIVES, SCOPE, AND METHODOLOGY................................................3 

 Objectives ...................................................................................................3 

Scope and Methodology .............................................................................3 

 

RESULTS OF REVIEW..................................................................................................5 

 RELATIONSHIP BETWEEN PAYMENTS AND 

 DRUG ACQUISITION COSTS.......................................................................5 

Comparison of Group Purchasing Organization Member and 

 Nonmember Pharmacies ..........................................................................6 

Comparison of Rural and Nonrural Pharmacies .........................................7 

 DISPENSING FEES...............................................................................................8 

Estimated Average Part D Dispensing Fees ...............................................8 

Comparison of Part D and Medicaid Dispensing Fees ...............................8 

 

 RECOMMENDATION.....................................................................9 

 CENTERS FOR MEDICARE & MEDICAID SERVICES COMMENTS ...........9 

 OFFICE OF INSPECTOR GENERAL RESPONSE .............................................9 

OTHER MATTER: DISPENSING COSTS..................................................................10 

 

 SELECTED PHARMACIES’ ESTIMATES .........................................................10 

 

 RECENT STUDIES................................................................................................10 

 CENTERS FOR MEDICARE & MEDICAID SERVICES COMMENTS ...........11 

 OFFICE OF INSPECTOR GENERAL RESPONSE .............................................11 

iii
APPENDIXES 

A – SAMPLE DESCRIPTION 

 B – PROJECTION RESULTS 

C – PERCENTAGE DIFFERENCE BETWEEN PART D PAYMENTS AND DRUG 

ACQUISITION COSTS FOR EACH SELECTED PHARMACY 

D – AVERAGE DOLLAR DIFFERENCE BETWEEN PART D PAYMENTS AND 

DRUG ACQUISITION COSTS PER PRESCRIPTION FOR EACH SELECTED 

PHARMACY 

E – BREAKDOWN OF PRESCRIPTIONS ANALYZED 

F – SELECTED PHARMACIES’ AVERAGE PART D DISPENSING FEES 

G – CENTERS FOR MEDICARE & MEDICAID SERVICES COMMENTS 

iv
INTRODUCTION 

BACKGROUND 

Senate Request Letter 

In a letter dated June 6, 2006, 33 Senators requested that we analyze three issues related to local, 

community pharmacies’ participation in the Medicare Part D program: network adequacy, 

contracting, and reimbursement. With respect to reimbursement, the Senators requested that we 

analyze reimbursement from Medicare prescription drug plans to local, community pharmacies 

relative to the pharmacies’ costs of acquiring and dispensing prescription drugs.1

 Additionally, 

the Senators stated: “We are also concerned about the sufficiency of reimbursement that local, 

community pharmacies receive from Medicare prescription drug plans. Pharmacists have 

informed us that in many cases, reimbursements fall well below their costs, which will 

undermine the long-term viability of local pharmacies and the MMA [Medicare Prescription 

Drug, Improvement, and Modernization Act] goal of ensuring beneficiaries’ access to them.” 

This report addresses the reimbursement aspect of the request. We have issued a separate report 

addressing network adequacy (OEI-05-06-00320), and we will address contracting in two 

upcoming reports. 

Medicare Part D Reimbursement of Drugs 

Title I of the Medicare Prescription Drug, Improvement, and Modernization Act of 2003 

significantly expanded the Medicare program set forth in Title 18 of the Social Security Act by 

establishing the Medicare Part D prescription drug program. Under Part D, which began 

January 1, 2006, individuals entitled to benefits under Part A or enrolled in Part B may obtain 

drug coverage. Covered drugs include drugs and biological products dispensed by prescription, 

as well as insulin and supplies associated with insulin injection.2

Unlike Parts A and B of the Medicare program, under which Medicare acts as the payer and 

insurer and generally pays on a fee-for-service basis, the prescription drug benefit is based on a 

private market model. The Centers for Medicare & Medicaid Services (CMS) contracts with 

prescription drug plans and Medicare Advantage plans, which then act as the payers and insurers 

for prescription drug benefits. CMS refers to these private entities as Part D sponsors. Retail 

pharmacies contract with Part D sponsors to obtain reimbursement for prescription drugs 

dispensed to Part D beneficiaries. The sponsors pay pharmacies a rate for ingredient costs (i.e., 

drug acquisition costs), usually a published average wholesale price of the drug minus some 

percentage, as well as a dispensing fee. Dispensing fees help pharmacies cover the costs of 

filling prescriptions. According to a recent study, dispensing costs could include such costs as 

 

1

We defined local, community pharmacies as independent retail or franchise retail pharmacies for this review. 

2

Title 18 of the Social Security Act, sections 1860D-1(a)(2) and (3)(A) and 1860D-2(e)(1)(A) and (B). 

1
payroll for prescription department employees and facility costs (e.g., rent, utilities, and 

maintenance costs).3

 

National Council for Prescription Drug Programs Pharmacy Database

The National Council for Prescription Drug Programs, Inc. (NCPDP), maintains a database of 

licensed pharmacies. As of October 2, 2006, the NCPDP Pharmacy Database contained 59,848 

retail pharmacies in the United States and Puerto Rico classified as chain, independent, or 

franchise. As defined by NCPDP, a chain pharmacy is part of a group of four or more 

pharmacies under common ownership; an independent pharmacy is part of a group of three or 

fewer pharmacies under common ownership; and a franchise pharmacy is independently owned 

but has a franchise agreement with another company to receive marketing, training, and/or other 

support.4 5 

National Drug Codes 

The Drug Listing Act of 1972 requires registered drug establishments to provide the Food and 

Drug Administration with a list of all drugs manufactured, prepared, propagated, compounded, 

or processed for commercial distribution.6 Drug establishments identify and report drugs using a 

unique, three-segment number called the National Drug Code (NDC), which is a universal 

product identifier for drugs for human use. The first segment, the labeler code, identifies the 

labeler, which is any firm that manufactures or distributes (under its own name) the drug. The 

second segment, the product code, identifies a specific strength, dosage form, and formulation 

for a particular labeler. The third segment, the package code, identifies the package size and 

type. 

First DataBank, Inc., Drug Database

The National Drug Data File PlusTM, maintained by First DataBank, Inc., includes descriptive 

information for all drugs approved by the Food and Drug Administration. The database contains, 

by NDC, such information as whether a drug is prescribed or purchased over the counter, 

whether a drug is brand name or generic, a product’s package size, and the number of packages 

in a case. Additionally, one data field contains the clinical formulation identification, which is a 

six-digit number used to aggregate drugs that share like ingredient sets, strength, dosage form, 

and route of administration (e.g., oral or injection) but are marketed by multiple manufacturers. 

Each like product receives the same identification number. 

 

3

Grant Thornton LLP, “National Study To Determine the Cost of Dispensing Prescriptions in Community Retail 

Pharmacies.” Available online at http://www.alphanet.org. Accessed on May 14, 2007. 

4

“Pharmacy Update.” Available online at http://www.ncpdp.org/provider_update.asp. Accessed on July 24, 2007. 

5

According to the National Association of Chain Drug Stores, chain drugstores filled 70.9 percent of the 3.42 billion 

prescriptions filled in 2006, independent pharmacies filled 21.1 percent, and franchise pharmacies filled 1.2 percent. 

Mail-order pharmacies accounted for the remaining prescriptions. 

6

This requirement is codified at 21 U.S.C. § 360(j).

2
OBJECTIVES, SCOPE, AND METHODOLOGY 

Objectives 

Our objectives were to (1) analyze the relationship between Medicare Part D payments, 

excluding dispensing fees, to local, community pharmacies and the pharmacies’ drug acquisition 

costs and (2) estimate Part D dispensing fees and compare them with Medicaid dispensing fees. 

Scope and Methodology 

Using the NCPDP Pharmacy Database, we identified 21,331 independent and franchise retail 

pharmacies in the United States and Puerto Rico. We included each pharmacy in our population 

four times to represent the 4 weeks7

 in September 2006. The population thus consisted of 

85,324 pharmacy weeks. We randomly selected 100 of these pharmacy weeks for review

Appendix A for a detailed description of our statistical sample design.) 

. (See 

The selected pharmacy weeks related to 99 pharmacies in 38 States and Puerto Rico.8

 As 

Table 1 shows, these pharmacies received payments totaling $1,114,845 for the drugs in 18,864 

Part D prescriptions (3,344 unique NDCs) and $42,959 in dispensing fees during the selected 

pharmacy weeks. 

Table 1: Part D Payments to Selected Pharmacies

Number of 

Prescriptions 

Drug 

Payments 

Dispensing Fee 

Payments 

Brand-name drugs 8,024 $895,194 $16,874 

Generic drugs 10,840 219,651 26,085 

Total 18,864 $1,114,845 $42,959 

Sixty-four of the selected pharmacies received rebates, and 66 belonged to GPOs.9 On average, 

according to estimates provided by officials at the selected pharmacies, the pharmacies filled 

more than 4,200 prescriptions each month, almost 32 percent of which were for Medicare Part D 

 

7

We defined a week as a 5-day span of weekdays, excluding Federal holidays. 

8

Although we reviewed 100 pharmacies, we excluded the results from 1 pharmacy because it received Part D 

payments for only two prescriptions during the selected week, and the percentage difference between Part D 

payments and drug acquisition costs was more than three times higher than that of the next highest selected 

pharmacy. As a result, all percentage and dollar estimates in this report are based on results at 99 pharmacies. 

However, the estimated number of pharmacies that received rebates and pharmacies that were members of group 

purchasing organizations (GPO) are based on results at all 100 pharmacies. 

9

As members of GPOs, small pharmacies receive the benefits of volume purchasing by leveraging their combined 

purchasing power to negotiate discount pricing from wholesalers or, in some cases, manufacturers. (“Follow the 

Pill: Understanding the U.S. Commercial Pharmaceutical Supply Chain,” prepared for the Kaiser Family 

Foundation by The Health Strategies Consultancy, LLC. Available online at http://www.kff.org/rxdrugs/7296.cfm. 

Accessed on May 4, 2007.) 

3
beneficiaries, and purchased about $184,000 worth of drugs through one or more wholesalers.10 

(Twenty-five of the pharmacies used only one wholesaler.) 

From December 2006 to April 2007, we visited the selected pharmacies to obtain data necessary 

to compare the Medicare Part D payments that the pharmacies received with their drug 

acquisition costs. During each pharmacy audit, we: 

• discussed Part D reimbursement and drug acquisition costs with pharmacy officials; 

• reviewed reimbursement data (remittance advices) that Part D sponsors and other payers 

sent to the pharmacy, Part D claim data that the pharmacy submitted to Part D sponsors, 

and drug purchase invoices; 

• determined Part D reimbursement for the week by matching remittance advices to Part D 

claim information from the pharmacy’s computer system; 

• determined drug acquisition costs by identifying drugs that the pharmacy purchased 

before the date each prescription was filled11 and by matching the reimbursed drug to a 

purchase of (1) the same drug and package size, (2) the same drug with a different 

package size when we could not find a match under the first method (after obtaining the 

pharmacy’s concurrence for these substitutions), or (3) a drug with the same clinical 

formulation identification when we could not find a match using the previous two 

methods (after obtaining the pharmacy’s concurrence for these substitutions); 

• calculated the difference between Part D reimbursement, excluding dispensing fees, and 

the pharmacy’s drug acquisition costs, both including and excluding rebates, if 

applicable;12 

• calculated the average Part D dispensing fees for all drugs, brand-name drugs, and 

generic drugs; and 

• issued a separate report to the pharmacy describing the results of our analysis. 

For this report, we used the calculations from the individual pharmacy audits to estimate the 

difference between Part D reimbursement and drug acquisition costs and the average Medicare 

dispensing fees across the population of local, community pharmacies. We also compared the 

calculations for (1) pharmacies that used GPOs versus those that did not and (2) rural versus 

nonrural pharmacies. To analyze the data on rural and nonrural pharmacies, we used a CMS file 

that classified ZIP Codes as rural, suburban, or urban based on population density. We grouped 

 

10The average monthly prescriptions and Part D percentage were based on estimates provided by 97 pharmacies, 

while the average monthly drug purchase information was based on estimates provided by 98 pharmacies. 

11We used data for purchases on or after the prescription fill dates for 308 of the 18,864 prescriptions we analyzed 

(after obtaining pharmacy officials’ concurrence). 

12We did not verify the actual rebates received from drug wholesalers; instead, we relied on pharmacy officials’ 

estimates.

4
the suburban and urban categories together in the nonrural category for estimation purposes. 

(See Appendix B for all statistical estimates in this report.) Using CMS data, we also calculated 

the average Medicaid dispensing fees paid by each State and the District of Columbia for 

comparison with Medicare Part D dispensing fees. 

We did not determine each selected pharmacy’s cost of dispensing drugs. The amount of work 

necessary to do so was prohibitive, and individual pharmacy cost structures vary substantially. 

Instead, we obtained cost estimates from the selected pharmacies and researched recent studies 

of dispensing costs. 

Because our objectives did not require an understanding or assessment of the selected 

pharmacies’ overall internal control structures, we did not perform such a review. We limited 

our review of internal controls to obtaining an understanding of how the pharmacies maintained 

Part D reimbursement and drug purchase data. 

We conducted our review in accordance with generally accepted government auditing standards. 

RESULTS OF REVIEW 

Medicare Part D payments, excluding dispensing fees, to local, community pharmacies exceeded 

the pharmacies’ drug acquisition costs by an estimated 18.1 percent when our analysis included 

rebates that drug wholesalers paid to pharmacies. Excluding rebates, Part D payments exceeded 

drug acquisition costs by an estimated 17.3 percent. The estimated difference between Part D 

payments and drug acquisition costs was $9.13 per prescription including rebates and $8.78 

excluding rebates. 

The estimated average Medicare Part D dispensing fee paid to local, community pharmacies was 

$2.27 per prescription, about $2 less than the average Medicaid dispensing fee. 

RELATIONSHIP BETWEEN PAYMENTS AND DRUG ACQUISITION COSTS 

All estimates in this section on the relationship between payments and drug acquisition costs 

exclude dispensing fees from Medicare Part D payments. We determined the percentage 

difference between Part D payments and drug acquisition costs for each selected pharmacy by 

subtracting drug acquisition costs from Part D payments and dividing by drug acquisition costs. 

Including rebates in our analysis, Medicare Part D payments to local, community pharmacies 

were an estimated 18.1 percent higher than drug acquisition costs. For the selected pharmacies, 

Part D payments ranged from 1.9 percent to 55.1 percent higher than drug acquisition costs. 

(Based on the 64 selected pharmacies that received wholesaler rebates, we estimated that 13,652 

of the 21,331 local, community pharmacies in our population received rebates, thus reducing 

their drug acquisition costs.) Excluding rebates from our analysis, Part D payments were an 

estimated 17.3 percent higher than drug acquisition costs. (See Appendix C for each selected 

pharmacy’s percentage difference between Part D payments and drug acquisition costs.) 

5
The Part D payment for each prescription exceeded drug acquisition costs by an estimated $9.13 

including rebates and $8.78 excluding rebates. (See Appendix D for each selected pharmacy’s 

average dollar difference per prescription.) 

Table 2 provides the estimated percentage and dollar differences both including and excluding 

rebates. 

Table 2: Estimated Difference Between Part D Payments and Drug Acquisition Costs

Estimated Difference 

as a Percentage of Costs 

Estimated Dollar Difference 

per Prescription 

 

 

Including 

Rebates 

Excluding 

Rebates 

Including 

Rebates 

Excluding 

Rebates 

All drugs 18.1% 17.3% $9.13 $8.78 

Brand-name drugs 7.9% 7.6% 9.18 8.86 

Generic drugs 73.3% 69.0% 9.12 8.77 

The percentage difference between Part D payments and drug acquisition costs was more than 

nine times higher for generic drugs than for brand-name drugs. However, generic and brandname drugs had similar per prescription dollar differences. 

Pharmacies almost always acquired drugs for less than their reimbursement amounts. For the 

18,864 Part D prescriptions we analyzed, payments were higher than drug acquisition costs for 

18,245 prescriptions (96.7 percent) and equal to or less than drug acquisition costs for 619 

prescriptions (3.3 percent).13 (Appendix E provides, for each selected pharmacy, the number of 

prescriptions analyzed, the number of prescriptions with Part D payments higher than drug 

acquisition costs, and the number of prescriptions with Part D payments equal to or below drug 

acquisition costs.) 

Comparison of Group Purchasing Organization 

Member and Nonmember Pharmacies 

Based on the 66 selected pharmacies that were members of GPOs, we estimated that 14,078 of 

the 21,331 pharmacies in our population were members of GPOs. Including rebates, Part D 

payments to GPO member pharmacies were an estimated 18.3 percent higher than drug 

acquisition costs, and payments to nonmember pharmacies were an estimated 17.7 percent 

higher. Table 3 presents the estimated percentage difference between Part D payments and drug 

acquisition costs for GPO members and nonmembers both including and excluding rebates.

 

13Payments were equal to drug acquisition costs for 9 prescriptions and less than drug acquisition costs for 610 

prescriptions.

6
Table 3: Estimated Difference Between Part D Payments and Drug Acquisition Costs 

for GPO Members and Nonmembers

GPO Members Nonmembers 

 

Including 

Rebates 

Excluding 

Rebates 

Including 

Rebates 

Excluding 

Rebates 

All drugs 18.3% 17.2% 17.7% 17.4% 

Brand-name drugs 8.3% 8.0% 7.1% 6.8% 

Generic drugs 73.7% 68.0% 72.6% 71.0% 

The difference between GPO members and nonmembers appears to be related to the fact that 

members received rebates on more drugs. For 1,351 drugs common to both GPO members and 

nonmembers, we found that members received rebates on 78 percent of the drugs and that 

nonmembers received rebates on 52 percent. 

Comparison of Rural and Nonrural Pharmacies 

CMS classified 11,528 pharmacies in our population as rural and 9,785 pharmacies as 

nonrural.14 Including rebates, Part D payments to rural pharmacies were an estimated 18.9 

percent higher than drug acquisition costs, and payments to nonrural pharmacies were an 

estimated 17.3 percent higher. Table 4 presents the estimated percentage difference between 

Part D payments and drug acquisition costs for rural and nonrural pharmacies both including and 

xcluding rebates. 

Table 4: Estimated Diff Drug Acquisition Costs 

for Rural and Nonrural Pharmacies

Rural Pharmacies Nonrural Pharmacies 

e

erence Between Part D Payments and 

 

Including 

Rebates 

Excluding 

Rebates 

Including 

Rebates 

Excluding 

Rebates 

All drugs 18.9% 17.9% 17.3% 16.6% 

Brand-name drugs 

Generic drugs 71.2% 66.4% 75.3% 71.5% 

 8.3% 7.9% 7.5% 7.3% 

The difference between rural and nonrural pharmacies appears to be related to the mix of generic

and brand-name drugs dispensed rather than a difference in Part D payment rates. Payments to

rural and nonrural pharmacies were nearly identical for 1,396 drugs common to both groups. 

Rural pharmacies, on the other hand, filled more generic prescriptions. Generic drugs accounted 

 

ug acquisition costs was significantly 

higher for generic drugs than for brand-name drugs. 

 

for 63 percent of the prescriptions filled by the selected rural pharmacies, compared with

52 percent of the prescriptions filled by nonrural pharmacies. As noted previously, the 

percentage difference between Part D payments and dr

14The CMS file that classified ZIP Codes as rural, urban, or suburban did not include classifications for 

18 pharmacies in our population. 

7
DISPENSING FEES 

Estimated Average Part D Dispensing Fees 

The estimated average Medicare Part D dispensing fee paid to local, community pharmacies for 

all drugs was $2.27 per prescription. Table 5 presents the estimated average Part D dispensing 

fees, as well as the lowest and highest average fees paid to the selected pharmacies. (Appendix F 

presents the average Part D dispensing fee for each selected pharmacy.) 

Table 5: Estimated Average Part D Dispensing Fees and 

Lowest and Highest Average Fees for the Selected Pharmacies 

Selected Pharmacies’ 

Average Dispensing Fees 

 

Number of 

Prescriptions 

Analyzed 

Estimated 

Average 

Part D 

Dispensing 

Fee 

Lowest Highest 

All drugs 18,864 $2.27 $1.40 $4.84 

Brand-name drugs 8,024 2.11 1.28 3.89 

Generic drugs15 10,840 2.36 1.38 5.41 

Comparison of Part D and Medicaid Dispensing Fees 

The average Medicaid dispensing fee paid during September 2006 was $4.30 per prescription, 

which was $2.03 more than the estimated average Part D dispensing fee of $2.27.16 Table 6 

compares the estimated average Medicare Part D dispensing fees with the average Medicaid 

dispensing fees. 

Table 6: Comparison of Medicare Part D and Medicaid Dispensing Fees

Estimated 

Average 

Part D 

Dispensing 

Fee 

Average 

Medicaid 

Dispensing 

Fee 

Difference 

All drugs $2.27 $4.30 $2.03 

Brand-name drugs 2.11 4.19 2.08 

Generic drugs 2.36 4.42 2.06 

 

15One Part D sponsor paid 31 selected pharmacies an enhanced dispensing fee that ranged from $0.80 to $1.80 per 

prescription, depending on the percentage of prescriptions filled using generic drugs. Of the 18,864 prescriptions we 

analyzed, only 911 were generic drug prescriptions eligible for this enhanced fee. We did not quantify the effect of 

the additional fee because it would have been minimal. 

16We based the average Medicaid dispensing fee on dispensing fees paid by 49 States and the District of Columbia. 

We excluded one State because its data were not comparable to other States’ data in that the State did not 

specifically identify dispensing fees paid to retail pharmacies. 

8
Officials from the selected pharmacies voiced concerns related to dispensing fee payments for 

beneficiaries entitled to Medicare and eligible for Medicaid (dually eligible beneficiaries). 

Before the implementation of Medicare Part D, Medicaid covered prescription drugs dispensed 

to these beneficiaries; however, when Medicare Part D was implemented, dually eligible 

beneficiaries were automatically enrolled in Part D prescription drug plans. As a result, 

pharmacies received the lower Medicare dispensing fees for these individuals. 

RECOMMENDATION 

We recommend that Congress and CMS consider the results of our review, including the data 

provided, in any deliberations regarding Medicare Part D reimbursement. 

 

CENTERS FOR MEDICARE & MEDICAID SERVICES COMMENTS 

In its written comments on our draft report, CMS concurred with our recommendation and stated 

that our findings were generally consistent with its own expectations. CMS also stated that the 

following aspects of our methodology were unclear: 

• how we applied pharmacy officials’ rebate estimates to the audited Part D claims and 

how these estimates could affect the percentage differences between Part D payments and 

drug acquisition costs, 

• how we determined the acquisition cost of a drug with the same clinical formulation 

identification as the drug for which the pharmacy billed Part D, and 

• how we calculated average Part D dispensing fees. 

OFFICE OF INSPECTOR GENERAL RESPONSE

We have clarified our methodology below: 

• We applied pharmacy officials’ rebate estimates to drug acquisition costs, not to Part D 

claims. We reduced each selected pharmacy’s drug acquisition costs by its estimated 

rebate percentage. We relied on the information provided to us by pharmacy officials 

familiar with their pharmacies’ rebate terms and did not verify the actual rebates 

received.

• When identifying drug acquisition costs, we tried to match those costs with the same 

drugs for which the pharmacy billed Part D; however, pharmacies sometimes substituted 

a like drug for the billed drug (i.e., a drug with the same clinical formulation 

identification but a different manufacturer). We were able to obtain the acquisition cost 

for the same drug billed to Part D for 90 percent of the analyzed prescriptions. For the 

remaining 10 percent, we obtained pharmacy officials’ concurrence to use the acquisition 

cost of a drug with the same clinical formulation identification. 

• We obtained data identifying the dispensing fees that Part D sponsors paid to the selected 

pharmacies from reimbursement data (remittance advices) or the contracts between the 

9
pharmacies and the Part D sponsors. We calculated the average Part D dispensing fee for 

each selected pharmacy by totaling the dispensing fees paid by Part D sponsors and 

dividing these totals by the number of Part D prescriptions. 

OTHER MATTER: DISPENSING COSTS 

Although this report provides estimates of the percentage and per prescription dollar differences 

between Part D ingredient cost payments and drug acquisition costs, the pharmacies’ incurred 

costs to dispense drugs would need to be factored into the calculation to derive the net difference 

between total Part D payments (i.e., ingredient cost payments plus dispensing fees) and total 

pharmacy costs (i.e., drug acquisition costs and dispensing costs, such as payroll for prescription 

department employees and facility costs). Following are the selected pharmacies’ estimates of 

dispensing costs and the results of two recent studies. 

SELECTED PHARMACIES’ ESTIMATES 

Of the 99 selected pharmacies, 69 pharmacies provided estimates of their costs to dispense 

prescription drugs based on various methods, including dividing total expenses by total 

prescriptions filled and using a formula created by a third-party contractor. The estimates ranged 

from $3.50 to $19 per prescription and averaged $9.13. The remaining 30 selected pharmacies 

did not provide estimates of their dispensing costs. 

Given the scope of our review, we did not ask pharmacy officials to provide documentation 

supporting their estimated dispensing costs. Therefore, we were unable to assess the accuracy of 

those estimates. 

RECENT STUDIES 

Two recent studies conducted on behalf of pharmacy associations both concluded that 

pharmacies’ costs to dispense prescription drugs averaged about $10.50 per prescription. 

• Grant Thornton LLP conducted a study for the Coalition for Community Pharmacy 

Action17 and issued “National Study To Determine the Cost of Dispensing Prescriptions 

in Community Retail Pharmacies” in January 2007.18 During this study, Grant Thornton 

LLP analyzed 6 months of data from 23,152 pharmacies and computed an average 

dispensing cost of $12.10. However, Grant Thornton LLP computed a weighted average 

dispensing cost of $10.50 per prescription because of substantial variations in the number 

of prescriptions filled per pharmacy. According to the report, high-volume pharmacies 

had significantly lower dispensing costs per prescription than low-volume pharmacies. 

 

17The coalition is an alliance between the National Association of Chain Drug Stores and the National Community 

Pharmacists Association (NCPA). 

18Available online at http://www.alphanet.org. Accessed on May 14, 2007. 

10
• The “2006 NCPA-Pfizer Digest”19 concluded that pharmacies’ average cost to dispense 

prescription drugs was $10.53, $1.29 more than the previous year’s estimate of $9.24. 

According to the information in the digest, expenses increased as stores added new 

personnel; stayed open longer; and provided value-added services, such as educating 

patients about Medicare Part D. 

We did not audit the results of these two studies. 

CENTERS FOR MEDICARE & MEDICAID SERVICES COMMENTS 

CMS said that its primary concern with our draft report was the inclusion of estimated 

dispensing costs provided by the selected pharmacies, as well as the calculated dispensing costs 

from two pharmacy association studies. CMS stated that these dispensing costs were potentially 

nonrepresentative and could obscure the ongoing Medicare Part D pharmacy debate. While 

acknowledging that the report stated that we had not reviewed the accuracy of the dispensing 

cost estimates or study results, CMS said that the statement would not prevent readers from 

relying on those data.

OFFICE OF INSPECTOR GENERAL RESPONSE 

As explained above, the dispensing cost information provides a more complete picture of 

pharmacies’ operations. We included the information because we did not want readers to 

misinterpret the differences between Part D payments and drug acquisition costs presented in the 

report as representing the difference between total pharmacy reimbursement and total pharmacy 

costs. The dispensing cost information clarifies that our analysis did not account for all of the 

costs associated with dispensing prescription drugs.

 

19The “2006 NCPA-Pfizer Digest” is a summary of selected financial and demographic information for independent 

community pharmacies. Available for purchase online at http://www.ncpanet.org. 

11
APPENDIXES 
APPENDIX A 

Page 1 of 3 

 

SAMPLE DESCRIPTION 

AUDIT OBJECTIVES

Our objectives were to (1) analyze the relationship between Medicare Part D payments, 

excluding dispensing fees, to local, community pharmacies and the pharmacies’ drug acquisition 

costs and (2) estimate Part D dispensing fees and compare them with Medicaid dispensing fees. 

POPULATION 

The sampling population consisted of the 21,331 independent and franchise retail pharmacies 

(local, community pharmacies) in the United States and Puerto Rico with National Council for 

Prescription Drug Programs, Inc. (NCPDP), provider numbers as of October 2, 2006. We 

included each pharmacy in our population four times to represent the 4 weeks in September 

2006. As a result, the population size was 85,324 (21,331 x 4).1

 

SAMPLING FRAME

The NCPDP Pharmacy Database included pharmacies in the U.S. territories of Guam and the 

Virgin Islands, as well as the Commonwealth of the Northern Mariana Islands. We removed the 

42 independent retail pharmacies in these locations from our population. (No franchise retail 

pharmacies were shown in these locations.) 

Additionally, we used a Centers for Medicare & Medicaid Services list of pharmacies that 

participated in Medicare Part D to identify pharmacies that did not participate. We removed the 

1,260 nonparticipating pharmacies (1,257 independent retail pharmacies and 3 franchise retail 

pharmacies) from our population. 

Each of the 21,331 local, community pharmacies appeared four times in the sampling frame, one 

time for each of the 4 pharmacy weeks in September 2006. 

SAMPLE UNIT

The sample unit was a pharmacy week (a 5-day span of weekdays, excluding Federal holidays) 

of Medicare Part D payments. For each sampled pharmacy week, we obtained data related to 

every prescription drug reimbursed by Medicare Part D and the pharmacy’s invoice price for 

each reimbursed drug. We calculated the percentage difference between the total Medicare 

Part D payments and the drug acquisition costs. 

 

1

Our original population included 21,346 local, community pharmacies with 85,384 pharmacy weeks (21,346 x 4). 

However, we removed 15 pharmacies from the population for the reasons cited in the “Treatment of Missing Sample 

Items” section of this appendix. 
APPENDIX A 

Page 2 of 3 

SAMPLE DESIGN

We used a two-phase sample design. The first phase entailed selecting a random sample of 

300 pharmacy weeks. Our survey work revealed that the payment cycles for third-party payers, 

including Part D sponsors, typically ranged from 15 to 45 days. As a result, some pharmacies 

might not have received a remittance advice with a Medicare Part D payment during a given 

week. We contacted the 300 pharmacies to determine whether they had received a remittance 

advice with a Medicare Part D payment during the selected pharmacy week. That helped ensure 

that we had 100 viable sample units by reducing the number of sample units that needed to be 

replaced because a pharmacy did not receive a Medicare Part D payment during the pharmacy 

week. 

In the second phase, we selected a random subsample of 125 pharmacy weeks from the 

pharmacies we confirmed to have received Medicare Part D payments during the selected 

pharmacy weeks. (The first 100 were our initial sample units, and the remaining 25 were used 

for replacements when needed.) 

SAMPLE SIZE

We selected 100 pharmacy weeks. 

SOURCE OF RANDOM NUMBERS

We generated the random numbers using the Office of Inspector General, Office of Audit 

Services, RAT-STATS statistical sampling software. 

METHOD OF SELECTING SAMPLE ITEMS

Each NCPDP provider number was replicated four times and assigned a numerical indicator 

from 1 to 4 signifying the 4 pharmacy weeks in September 2006. We numbered the resulting 

85,324 sample items sequentially from 1 to 85,324 and generated 300 random numbers based on 

them. 

We also generated 125 random numbers based on the sequential numbers of those pharmacies 

we confirmed to have received Medicare Part D payments during the selected pharmacy weeks. 

CHARACTERISTICS TO BE MEASURED 

We obtained from the sampled pharmacies (1) remittance advice data for the selected pharmacy 

week, (2) Medicare Part D claim data for prescription fill dates included in the remittance advice 

data, and (3) invoice data for at least 3 months before the earliest fill date of any Medicare Part D 

payments received during the pharmacy week. By matching common data elements from these 

three data sets (e.g., prescription number and prescription fill date), we calculated the total 

Medicare Part D payments for the pharmacy week and the associated drug acquisition costs. We 

used the total payments and acquisition costs to calculate the percentage difference between 

payments and costs. 
APPENDIX A 

Page 3 of 3 

TREATMENT OF MISSING SAMPLE ITEMS

If 1 of the initial 300 pharmacies we contacted was out of business; did not participate in 

Medicare Part D; or was not a local, community pharmacy, we removed the pharmacy week 

from the sample and all 4 pharmacy weeks for the pharmacy from the population. If one of these 

pharmacies did not receive a Medicare Part D payment during the selected pharmacy week but 

participated in Medicare Part D, we removed the pharmacy week from the sample but not from 

the population. We left all 4 pharmacy weeks in the population. 

If 1 of the 100 pharmacies selected for a site visit had gone out of business between the date of 

initial contact to determine whether it had received a Medicare Part D payment during the 

selected pharmacy week and the date of our site visit, we replaced that pharmacy week with a 

spare from the subsample and removed all 4 pharmacy weeks for the pharmacy from our 

population. If 1 of the 100 pharmacies selected for a site visit could not produce all of the data 

necessary for our analysis, we replaced the pharmacy week with a spare from the subsample but 

left all 4 pharmacy weeks in the population. 

ESTIMATION METHODOLOGY

We used the RAT-STATS variable appraisal program for simple random samples to estimate the 

differences between Medicare Part D payments and acquisition costs and to estimate average 

Part D dispensing fees. We used the RAT-STATS attribute appraisal program for simple 

random samples to estimate the number of pharmacies that received rebates and that were 

members of group purchasing organizations. 

We estimated the sample mean along with the 90-percent two-sided confidence interval. 
APPENDIX B 

Page 1 of 3 

 

PROJECTION RESULTS

90-Percent Confidence Level 

Variable Appraisal Description1 Mean Precision 

Amount 

Lower 

Limit 

Upper 

Limit 

All pharmacies: 

Percentage difference between payments and costs 

including rebates 

All drugs 18.1% 1.3% 16.8% 19.4%

Brand-name drugs 7.9 0.5 7.4 8.4

Generic drugs 73.3 5.9 67.4 79.2

Percentage difference between payments and costs 

excluding rebates 

All drugs 17.3 1.3 16.0 18.6

Brand-name drugs 7.6 0.5 7.1 8.1

Generic drugs 69.0 6.0 63.0 75.0

All pharmacies per prescription: 

Dollar difference between payments and costs including 

rebates 

All drugs $9.13 $1.05 $8.08 $10.18

Brand-name drugs 9.18 1.26 7.92 10.44

Generic drugs 9.12 1.13 7.94 10.25

Dollar difference between payments and costs excluding 

rebates 

All drugs 8.78 1.03 7.75 9.81

Brand-name drugs 8.86 1.25 7.61 10.11

Generic drugs 8.77 1.13 7.64 9.90

Group purchasing organization members: 

Percentage difference between payments and costs 

including rebates 

All drugs 18.3% 1.4% 16.9% 19.7%

Brand-name drugs 8.3 0.5 7.8 8.8

Generic drugs 73.7 7.7 66.0 81.4

Percentage difference between payments and costs 

excluding rebates 

All drugs 17.2 1.4 15.8 18.6

Brand-name drugs 8.0 0.5 7.5 8.5

Generic drugs 68.0 7.9 60.1 75.9

1

All variable appraisals in this appendix are based on the results at 99 pharmacies; all attribute appraisals are based on the results at 100 

pharmacies. 
APPENDIX B 

Page 2 of 3 

90-Percent Confidence Level 

Variable Appraisal Description Mean Precision 

Amount 

Lower 

Limit 

Upper 

Limit 

Group purchasing organization nonmembers: 

Percentage difference between payments and costs 

including rebates 

All drugs 17.7% 2.7% 15.0% 20.4%

Brand-name drugs 7.1 1.0 6.1 8.1

Generic drugs 72.6 9.4 63.2 82.0

Percentage difference between payments and costs 

excluding rebates 

All drugs 17.4 2.8 14.6 20.2

Brand-name drugs 6.8 1.0 5.8 7.8

Generic drugs 71.0 9.2 61.8 80.2

Rural pharmacies: 

Percentage difference between payments and costs 

including rebates 

All drugs 18.9% 1.5% 17.4% 20.4%

Brand-name drugs 8.3 0.7 7.6 9.0

Generic drugs 71.2 7.1 64.1 78.3

Percentage difference between payments and costs 

excluding rebates 

All drugs 17.9 1.5 16.4 19.4

Brand-name drugs 7.9 0.7 7.2 8.6

Generic drugs 66.4 7.3 59.1 73.7

Nonrural pharmacies: 

Percentage difference between payments and costs 

including rebates 

All drugs 17.3% 2.1% 15.2% 19.4%

Brand-name drugs 7.5 0.7 6.8 8.2

Generic drugs 75.3 9.6 65.7 84.9

Percentage difference between payments and costs 

excluding rebates 

All drugs 16.6 2.1 14.5 18.7

Brand-name drugs 7.3 0.7 6.6 8.0

Generic drugs 71.5 9.6 61.9 81.1
APPENDIX B 

Page 3 of 3 

90-Percent Confidence Level 

Variable Appraisal Description Mean Precision 

Amount 

Lower 

Limit 

Upper 

Limit 

All pharmacies: 

Part D dispensing fees 

All drugs $2.27 $0.10 $2.17 $2.37

Brand-name drugs 2.11 0.10 2.01 2.21 

Generic drugs 2.36 0.12 2.24 2.48 

90-Percent Confidence Level

Attribute Appraisal Description2 Characteristic 

of Interest Lower 

Limit 

Upper 

Limit 

 Pharmacies that received rebates 

Percentage 64.0% 55.371% 71.991%

Number 13,652 11,811 15,356

 Pharmacies that did not receive rebates 

Percentage 36.0% 28.009% 44.629%

Number 7,679 5,975 9,520

 Group purchasing organization members 

Percentage 66.0% 57.427% 73.844%

Number 14,078 12,250 15,752

 Group purchasing organization nonmembers 

Percentage 34.0% 26.156% 42.573%

Number 7,253 5,579 9,081

 

2

Because each pharmacy was represented four times in the sampling population, we estimated the number of pharmacies as one quarter the 

number of pharmacy weeks. 
AP

PERCENTAGE DIFFERENCE BETWEEN PART D PAYMENTS AND DRUG 

ACQUISITION COSTS FOR EACH SELECTED PHARMACY 

All Drugs Brand-Name Drugs Generic Dru

Sample 

Item 

Number 

of 

Prescriptions 

Analyzed1

Percentage 

Difference 

Including 

Rebates 

Percentage 

Difference 

Excluding 

Rebates 

Impact 

of 

Rebates 

Percentage 

Difference 

Including 

Rebates 

Percentage 

Difference 

Excluding 

Rebates 

Impact 

of 

Rebates 

Percentage 

Difference 

Including 

Rebates 

Percenta

Differen

Excludi

Rebate

9 13 55.1% 54.6% 0.5% -2 6.6% - 158.9% 155.

81 17 - 48.4 - - 8.7 - - 2633 17 40.9 38.2 2.7 8.4% 8.1 0.3% 86.7 746 158 - 35.3 - - 7.2 - - 1094 8 30.0 29.9 0.1 8.4 8.2 0.2 - 1973 59 30.2 28.6 1.6 - 13.4 - 119.0 10

2 91 - 27.0 - - 11.6 - - 8

14 71 - 26.8 - - 6.6 - - 1232 57 27.4 26.6 0.8 - 6.4 - 66.6 651 96 25.5 25.1 0.4 - 14.0 - 170.7 1531 269 - 24.7 - - 5.2 - - 785 79 30.6 24.5 6.1 5.4 5.3 0.1 70.4 515 242 25.2 24.3 0.9 8.8 7.7 1.1 - 644 17 - 23.2 - - 8.4 - - 492 321 25.8 22.6 3.2 8.3 6.7 1.6 84.7 736 151 22.7 22.0 0.7 9.6 9.0 0.6 67.2 668 225 23.7 21.8 1.9 8.8 7.3 1.5 103.5 960 62 22.2 21.6 0.6 - 9.9 - 92.2 887 306 22.5 21.4 1.1 9.9 8.8 1.1 55.2 577 81 21.2 20.8 0.4 8.6 8.2 0.4 51.6 5

8 466 22.5 20.7 1.8 - 10.3 - 79.7 6

41 549 20.6 20.2 0.4 - 10.5 - 69.8 6

4 52 - 20.1 - - 11.5 - - 6

95 53 23.5 20.0 3.5 9.4 9.3 0.1 68.4 5

1See Appendix E for a breakdown of the number of brand-name and generic drugs analyzed. 2A dash indicates that the sampled pharmacy did not receive a rebate. 
AP

All Drugs Brand-Name Drugs Generic Dr

Sample 

Item 

Number 

of 

Prescriptions 

Analyzed 

Percentage 

Difference 

Including 

Rebates 

Percentage 

Difference 

Excluding 

Rebates 

Impact 

of 

Rebates 

Percentage 

Difference 

Including 

Rebates 

Percentage 

Difference 

Excluding 

Rebates 

Impact 

of 

Rebates 

Percentage 

Difference 

Including 

Rebates 

Percen

Differe

Exclud

Reba

57 193 23.3 19.6 3.7 14.1 11.8 2.3 93.8 43 261 22.5 19.6 2.9 - 6.6 - 87.1 22 242 19.8 19.6 0.2 6.0 5.8 0.2 81.1 72 261 - 19.3 - - 8.4 - - 47 49 19.9 19.3 0.6 - 9.3 - 97.0 49 46 - 18.8 - - 12.8 - - 64 169 - 18.8 - - 6.7 - - 30 100 - 18.7 - - 7.1 - - 37 153 - 18.3 - - 10.8 - - 69 40 18.9 18.3 0.6 - 11.7 - 69.5 48 46 - 18.1 - - 8.8 - - 71 148 - 18.1 - - 6.7 - - 20 37 - 17.7 - - 7.6 - - 84 241 - 17.3 - - 9.3 - - 93 145 17.4 17.3 0.1 - 9.3 - 68.9 79 160 17.23 17.2 0.0 - 10.4 - 51.9 90 92 19.8 17.0 2.8 9.0 8.8 0.2 67.2 19 368 - 16.9 - - 7.3 - - 54 3 - 16.9 - - 12.1 - - 66 403 - 16.8 - - 7.9 - - 35 368 17.9 16.7 1.2 - 9.0 - 76.4 86 104 16.8 16.7 0.1 - 2.9 - 69.5 39 214 17.6 16.2 1.4 - 8.5 - 68.9 

3This pharmacy received a rebate on a few drugs during the selected pharmacy week, but the percentage was not affected. 
AP

All Drugs Brand-Name Drugs Generic Dr

Sample 

Item 

Number 

of 

Prescriptions 

Analyzed 

Percentage 

Difference 

Including 

Rebates 

Percentage 

Difference 

Excluding 

Rebates 

Impact 

of 

Rebates 

Percentage 

Difference 

Including 

Rebates 

Percentage 

Difference 

Excluding 

Rebates 

Impact 

of 

Rebates 

Percentage 

Difference 

Including 

Rebates 

Percen

Differe

Exclud

Reba

7 127 18.2 16.1 2.1 11.73 11.7 0.0 47.4 

34 620 16.4 16.0 0.4 - 8.3 - 75.8 97 51 - 15.9 - - 7.4 - - 74 41 16.4 15.7 0.7 - 6.9 - 59.7 45 84 - 15.2 - - 5.3 - - 56 52 - 15.2 - - 7.5 - - 75 215 18.4 15.2 3.2 9.1 6.6 2.5 85.2 67 175 15.3 15.1 0.2 - 6.0 - 59.1 18 67 17.7 15.1 2.6 5.9 5.8 0.1 47.3 58 76 15.3 14.9 0.4 9.0 8.7 0.3 69.3 38 113 - 14.8 - - 7.5 - - 59 274 18.1 14.8 3.3 8.6 8.5 0.1 52.2 16 201 14.9 14.7 0.2 9.6 9.4 0.2 - 

1 495 15.0 14.6 0.4 - 8.6 - 41.6 

83 99 16.6 14.5 2.1 9.9 9.0 0.9 44.2 11 212 14.6 14.4 0.2 6.13 6.1 0.0 118.8 

6 230 14.8 14.4 0.4 - 6.2 - 59.2 

62 645 - 14.2 - - 8.0 - - 13 69 - 14.1 - - 7.2 - - 80 88 - 13.9 - - 8.8 - - 78 11 - 13.8 - - 7.4 - - 82 46 - 13.7 - - 9.7 - - 29 56 14.2 13.7 0.5 11.5 11.0 0.5 42.7 
AP

All Drugs Brand-Name Drugs Generic Dr

Sample 

Item 

Number 

of 

Prescriptions 

Analyzed 

Percentage 

Difference 

Including 

Rebates 

Percentage 

Difference 

Excluding 

Rebates 

Impact 

of 

Rebates 

Percentage 

Difference 

Including 

Rebates 

Percentage 

Difference 

Excluding 

Rebates 

Impact 

of 

Rebates 

Percentage 

Difference 

Including 

Rebates 

Percen

Differe

Exclud

Reba

63 200 14.3 13.6 0.7 - 6.5 - 61.9 27 35 14.0 13.6 0.4 9.6 9.2 0.4 22.4 17 63 14.2 13.1 1.1 10.2 9.1 1.1 97.8 98 83 14.9 12.9 2.0 - 9.0 - 55.1 52 79 13.7 12.9 0.8 8.0 7.3 0.7 34.6 99 656 - 12.8 - - 4.6 - - 61 140 13.4 12.8 0.6 - 6.6 - 81.0 50 380 12.53 12.5 0.0 - 5.1 - 79.4 96 512 12.7 12.3 0.4 - 6.7 - 92.4 53 108 14.7 12.2 2.5 5.9 5.7 0.2 59.3 91 157 12.5 12.2 0.3 6.3 6.0 0.3 47.6 55 7 - 12.1 - - 8.4 - - 40 224 13.1 12.1 1.0 7.6 6.5 1.1 - 21 378 12.3 12.1 0.2 - 6.1 - 98.7 23 845 12.2 12.1 0.1 - 6.1 - 72.0 

5 774 12.9 11.9 1.0 - 7.4 - 66.8 

76 669 - 11.6 - - 8.4 - - 70 16 - 10.9 - - 8.5 - - 89 859 14.4 10.7 3.7 6.9 3.2 3.7 73.0 25 117 11.4 10.6 0.8 4.8 4.5 0.3 69.1 

3 188 11.1 10.0 1.1 6.7 5.6 1.1 38.6 

24 41 10.8 8.9 1.9 9.0 7.0 2.0 - 26 122 9.8 8.5 1.3 6.7 5.3 1.4 - 
AP

All Drugs Brand-Name Drugs Generic Dr

Sample 

Item 

Number 

of 

Prescriptions 

Analyzed 

Percentage 

Difference 

Including 

Rebates 

Percentage 

Difference 

Excluding 

Rebates 

Impact 

of 

Rebates 

Percentage 

Difference 

Including 

Rebates 

Percentage 

Difference 

Excluding 

Rebates 

Impact 

of 

Rebates 

Percentage 

Difference 

Including 

Rebates 

Percen

Differe

Exclud

Reba

65 267 - 7.9 - - 4.7 - - 28 116 - 7.4 - - 1.3 - - 42 100 10.1 7.2 2.9 8.0 7.7 0.3 20.0 10 13 6.8 5.9 0.9 - 3.0 - 34.5 88 242 - 5.2 - - (3.1)4 - - 12 123 - 1.9 - - (4.5) - - 

4Amounts shown in parentheses represent an average cost above the Part D payment.
AVERAGE DOLLAR DIFFERENCE BETWEEN PART D PAYMENTS AND DRUG ACQUISITIO

PRESCRIPTION FOR EACH SELECTED PHARMACY 

All Drugs Brand-Name Drugs Generic 

Sample 

Item 

Number of 

Prescriptions 

Analyzed1

Dollar 

Difference 

Including 

Rebates 

Dollar 

Difference 

Excluding 

Rebates 

Impact 

of 

Rebates 

Dollar 

Difference 

Including 

Rebates 

Dollar 

Difference 

Excluding 

Rebates 

Impact 

of 

Rebates 

Dollar 

Difference 

Including 

Rebates 

Do

Diff

Exc

Re

81 17 -

2 $61.14 - - $39.25 - - 

55 7 - 26.27 - - 60.96 - - 26 122 $18.70 16.32 $2.38 $27.78 22.41 $5.37 - 51 96 16.44 16.24 0.20 - 20.08 - $13.84 17 63 16.87 15.71 1.16 25.19 22.80 2.39 9.77 49 46 - 13.91 - - 15.08 - - 

2 91 - 12.74 - - 13.09 - - 

94 8 12.59 12.54 0.05 4.95 4.86 0.09 - 36 151 12.68 12.36 0.32 10.13 9.48 0.65 14.46 

9 13 12.22 12.13 0.09 - 4.32 - 14.59 

80 88 - 11.60 - - 19.64 - - 31 269 - 11.40 - - 6.24 - - 32 57 11.63 11.36 0.27 - 5.27 - 14.80 79 160 11.36 11.33 0.03 - 14.33 - 9.38 60 62 11.33 11.10 0.23 - 11.61 - 11.17 46 158 - 10.91 - - 5.11 - - 83 99 11.78 10.48 1.30 15.10 13.88 1.22 9.79 73 59 10.87 10.44 0.43 - 13.33 - 9.80 14 71 - 10.11 - - 6.36 - - 16 201 10.09 9.94 0.15 11.26 10.97 0.29 - 47 49 10.08 9.80 0.28 - 8.09 - 12.15 38 113 - 9.79 - - 8.21 - - 

1See Appendix E for a breakdown of the number of brand-name and generic drugs analyzed. 2A dash indicates that the sampled pharmacy did not receive a rebate. 
 

All Drugs Brand-Name Drugs Generic 

Sample 

Item 

Number of 

Prescriptions 

Analyzed 

Dollar 

Difference 

Including 

Rebates 

Dollar 

Difference 

Excluding 

Rebates 

Impact 

of 

Rebates 

Dollar 

Difference 

Including 

Rebates 

Dollar 

Difference 

Excluding 

Rebates 

Impact 

of 

Rebates 

Dollar 

Difference 

Including 

Rebates 

Do

Diff

Exc

Re

82 46 - 9.74 - - 11.70 - - 43 261 10.76 9.59 1.17 - 8.33 - 11.81 68 225 10.21 9.52 0.69 8.71 7.31 1.40 11.07 74 41 9.69 9.37 0.32 - 8.62 - 10.37 57 193 10.80 9.37 1.43 13.43 11.48 1.95 8.82 98 83 10.57 9.31 1.26 - 10.92 - 10.21 11 212 9.36 9.28 0.08 6.62 6.59 0.03 12.67 58 76 9.46 9.24 0.22 9.73 9.35 0.38 9.17 69 40 9.47 9.21 0.26 - 17.04 - 6.23 87 306 9.59 9.18 0.41 10.14 9.11 1.03 9.35 84 241 - 9.02 - - 12.89 - - 29 56 9.03 8.76 0.27 10.42 10.02 0.40 6.52 33 17 9.10 8.68 0.42 3.72 3.58 0.14 11.35 

8 466 9.13 8.55 0.58 - 8.32 - 9.70 

62 645 - 8.51 - - 6.95 - - 97 51 - 8.51 - - 8.73 - - 45 84 - 8.15 - - 4.76 - - 67 175 8.22 8.13 0.09 - 6.49 - 9.43 

7 127 9.00 8.12 0.88 11.00 10.95 0.05 7.47 

35 368 8.56 8.09 0.47 - 10.23 - 7.61 75 215 9.45 8.03 1.42 8.79 6.55 2.24 10.04 65 267 - 8.00 - - 9.32 - - 
 

All Drugs Brand-Name Drugs Generic 

Sample 

Item 

Number of 

Prescriptions 

Analyzed 

Dollar 

Difference 

Including 

Rebates 

Dollar 

Difference 

Excluding 

Rebates 

Impact 

of 

Rebates 

Dollar 

Difference 

Including 

Rebates 

Dollar 

Difference 

Excluding 

Rebates 

Impact 

of 

Rebates 

Dollar 

Difference 

Including 

Rebates 

Do

Diff

Exc

Re

93 145 8.02 8.00 0.02 - 9.45 - 7.09 15 242 8.21 7.98 0.23 6.97 6.17 0.80 - 52 79 8.25 7.81 0.44 10.31 9.38 0.93 7.05 39 214 8.29 7.76 0.53 - 9.67 - 7.55 95 53 8.82 7.73 1.09 8.39 8.25 0.14 9.02 37 153 - 7.68 - - 7.53 - - 54 3 - 7.68 - - 7.97 - - 72 261 - 7.68 - - 7.07 - - 76 669 - 7.63 - - 8.02 - - 34 620 7.76 7.59 0.17 - 8.61 - 7.19 77 81 7.69 7.57 0.12 6.86 6.60 0.26 8.08 92 321 8.38 7.54 0.84 6.81 5.56 1.25 9.08 21 378 7.61 7.49 0.12 - 6.73 - 8.58 23 845 7.52 7.46 0.06 - 6.66 - 8.43 71 148 - 7.33 - - 5.36 - - 61 140 7.54 7.27 0.27 - 8.08 - 7.14 64 169 - 7.18 - - 6.33 - - 27 35 7.33 7.15 0.18 10.47 10.08 0.39 5.90 19 368 - 7.12 - - 6.59 - - 

1 495 7.28 7.11 0.17 - 9.29 - 6.15 5 774 7.49 7.00 0.49 - 6.71 - 8.61 6 230 7.06 6.91 0.15 - 6.18 - 7.66 
 

All Drugs Brand-Name Drugs Generic 

Sample 

Item 

Number of 

Prescriptions 

Analyzed 

Dollar 

Difference 

Including 

Rebates 

Dollar 

Difference 

Excluding 

Rebates 

Impact 

of 

Rebates 

Dollar 

Difference 

Including 

Rebates 

Dollar 

Difference 

Excluding 

Rebates 

Impact 

of 

Rebates 

Dollar 

Difference 

Including 

Rebates 

Do

Diff

Exc

Re

70 16 - 6.87 - - 7.00 - - 91 157 6.98 6.84 0.14 5.72 5.49 0.23 8.35 41 549 6.95 6.83 0.12 - 8.25 - 6.23 25 117 7.24 6.77 0.47 6.29 5.83 0.46 7.97 13 69 - 6.71 - - 6.82 - - 53 108 7.89 6.71 1.18 7.28 7.09 0.19 8.24 20 37 - 6.69 - - 5.09 - - 24 41 7.74 6.49 1.25 10.91 8.68 2.23 - 63 200 6.76 6.45 0.31 - 6.05 - 7.29 22 242 6.50 6.43 0.07 5.39 5.19 0.20 6.97 40 224 6.88 6.40 0.48 8.77 7.60 1.17 - 

4 52 - 6.35 - - 12.05 - - 

85 79 7.45 6.27 1.18 4.89 4.78 0.11 7.96 66 403 - 6.20 - - 6.50 - - 96 512 6.20 5.99 0.21 - 5.93 - 6.48 48 46 - 5.92 - - 7.19 - - 90 92 6.67 5.84 0.83 7.28 7.16 0.12 6.36 99 656 - 5.73 - - 4.29 - - 56 52 - 5.70 - - 6.38 - - 89 859 7.43 5.70 1.73 7.46 3.59 3.87 7.41 50 380 5.693 5.69 0.00 - 4.75 - 6.44 

3This pharmacy received a rebate on a few drugs during the selected pharmacy week, but the percentage was not affected. 
 

All Drugs Brand-Name Drugs Generic 

Sample 

Item 

Number of 

Prescriptions 

Analyzed 

Dollar 

Difference 

Including 

Rebates 

Dollar 

Difference 

Excluding 

Rebates 

Impact 

of 

Rebates 

Dollar 

Difference 

Including 

Rebates 

Dollar 

Difference 

Excluding 

Rebates 

Impact 

of 

Rebates 

Dollar 

Difference 

Including 

Rebates 

Do

Diff

Exc

Re

44 17 - 5.58 - - 6.77 - - 

3 188 6.05 5.50 0.55 6.09 5.18 0.91 6.01 

86 104 5.06 5.04 0.02 - 2.39 - 6.14 59 274 5.94 5.00 0.94 7.68 7.55 0.13 5.23 78 11 - 4.98 - - 5.00 - - 18 67 5.69 4.95 0.74 4.14 4.03 0.11 6.45 28 116 - 4.87 - - 1.58 - - 42 100 6.31 4.59 1.72 7.79 7.49 0.30 4.65 30 100 - 4.40 - - 4.38 - - 10 13 3.64 3.15 0.49 - 3.01 - 4.17 88 242 - 1.62 - - (3.12)4 - - 12 123 - 0.62 - - (3.72) - - 

4Amounts shown in parentheses represent an average cost above the Part D payment. 
BREAKDOWN OF PRESCRIPTIONS ANALYZED 

All Drugs Brand-Name Drugs Gener

Sample 

Item 

Number of 

Prescriptions 

Analyzed 

Number of 

Prescriptions 

for Which 

Payments > 

Costs 

Number of 

Prescriptions 

for Which 

Payments 

≤

Costs1

Number of 

Prescriptions 

Analyzed 

Number of 

Prescriptions 

for Which 

Payments > 

Costs 

Number of 

Prescriptions 

for Which 

Payments 

≤

Costs 

Number of 

Prescriptions 

Analyzed 

Num

Presc

for 

Paym

C

89 859 831 28 365 350 15 494 23 845 807 38 437 410 27 408 

5 774 749 25 454 454 0 320 

76 669 643 26 431 421 10 238 99 656 636 20 269 264 5 387 62 645 638 7 401 400 1 244 34 620 611 9 250 248 2 370 41 549 532 17 195 190 5 354 96 512 501 11 262 257 5 250 

1 495 476 19 179 179 0 316 8 466 456 10 194 192 2 272 

66 403 400 3 140 139 1 263 50 380 374 6 169 167 2 211 21 378 369 9 198 195 3 180 19 368 354 14 134 131 3 234 35 368 365 3 134 133 1 234 92 321 318 3 98 98 0 223 87 306 304 2 92 91 1 214 59 274 268 6 79 78 1 195 31 269 259 10 74 69 5 195 65 267 255 12 123 122 1 144 43 261 260 1 79 78 1 182 72 261 255 6 101 100 1 160 15 242 240 2 71 71 0 171 22 242 235 7 72 66 6 170 

1Payments equaled costs for nine prescriptions (two brand-name and seven generic prescriptions).
All Drugs Brand-Name Drugs Gener

Sample 

Item 

Number of 

Prescriptions 

Analyzed 

Number of 

Prescriptions 

for Which 

Payments > 

Costs 

Number of 

Prescriptions 

for Which 

Payments ≤

Costs 

Number of 

Prescriptions 

Analyzed 

Number of 

Prescriptions 

for Which 

Payments > 

Costs 

Number of 

Prescriptions 

for Which 

Payments ≤

Costs 

Number of 

Prescriptions 

Analyzed 

Num

Presc

for 

Paym

C

88 242 172 70 67 9 58 175 84 241 234 7 79 79 0 162 

6 230 220 10 93 90 3 137 

68 225 216 9 82 79 3 143 40 224 215 9 92 91 1 132 75 215 210 5 101 100 1 114 39 214 210 4 75 75 0 139 11 212 206 6 116 112 4 96 16 201 196 5 105 103 2 96 63 200 192 8 87 84 3 113 57 193 189 4 83 83 0 110 

3 188 179 9 97 97 0 91 

67 175 167 8 72 71 1 103 64 169 164 5 56 55 1 113 79 160 157 3 64 64 0 96 46 158 155 3 49 48 1 109 91 157 144 13 82 76 6 75 37 153 152 1 80 80 0 73 36 151 146 5 62 58 4 89 71 148 147 1 64 63 1 84 93 145 143 2 57 57 0 88 61 140 138 2 59 59 0 81 

7 127 123 4 55 53 2 72 

12 123 74 49 43 3 40 80 26 122 120 2 54 53 1 68 
All Drugs Brand-Name Drugs Gener

Sample 

Item 

Number of 

Prescriptions 

Analyzed 

Number of 

Prescriptions 

for Which 

Payments > 

Costs 

Number of 

Prescriptions 

for Which 

Payments ≤

Costs 

Number of 

Prescriptions 

Analyzed 

Number of 

Prescriptions 

for Which 

Payments > 

Costs 

Number of 

Prescriptions 

for Which 

Payments ≤

Costs 

Number of 

Prescriptions 

Analyzed 

Num

Presc

for 

Paym

C

25 117 112 5 51 49 2 66 28 116 110 6 57 53 4 59 38 113 109 4 59 58 1 54 53 108 107 1 39 38 1 69 86 104 101 3 30 29 1 74 30 100 89 11 21 18 3 79 42 100 97 3 53 53 0 47 83 99 99 0 37 37 0 62 51 96 95 1 40 40 0 56 90 92 90 2 31 31 0 61 

2 91 90 1 30 29 1 61 

80 88 87 1 29 29 0 59 45 84 82 2 45 43 2 39 98 83 82 1 42 41 1 41 77 81 79 2 26 26 0 55 52 79 74 5 29 28 1 50 85 79 78 1 13 13 0 66 58 76 75 1 39 39 0 37 14 71 69 2 23 21 2 48 13 69 69 0 31 31 0 38 18 67 67 0 22 22 0 45 17 63 56 7 29 26 3 34 60 62 62 0 23 23 0 39 73 59 59 0 18 18 0 41 32 57 55 2 19 19 0 38 
All Drugs Brand-Name Drugs Gener

Sample 

Item 

Number of 

Prescriptions 

Analyzed 

Number of 

Prescriptions 

for Which 

Payments > 

Costs 

Number of 

Prescriptions 

for Which 

Payments ≤

Costs 

Number of 

Prescriptions 

Analyzed 

Number of 

Prescriptions 

for Which 

Payments > 

Costs 

Number of 

Prescriptions 

for Which 

Payments ≤

Costs 

Number of 

Prescriptions 

Analyzed 

Num

Presc

for 

Paym

C

29 56 55 1 36 36 0 20 95 53 53 0 17 17 0 36 

4 52 51 1 13 13 0 39 

56 52 50 2 20 20 0 32 97 51 49 2 19 19 0 32 47 49 49 0 25 25 0 24 48 46 45 1 13 12 1 33 49 46 45 1 27 27 0 19 82 46 46 0 25 25 0 21 24 41 40 1 23 23 0 18 74 41 41 0 16 16 0 25 69 40 39 1 12 12 0 28 20 37 36 1 16 16 0 21 27 35 32 3 11 11 0 24 33 17 17 0 5 5 0 12 44 17 16 1 3 3 0 14 81 17 17 0 4 4 0 13 70 16 15 1 6 6 0 10 

9 13 13 0 3 3 0 10 

10 13 10 3 6 4 2 7 78 11 10 1 4 4 0 7 94 8 8 0 5 5 0 3 55 7 7 0 2 2 0 5 54 3 3 0 2 2 0 1 

Total 18,864 18,245 619 8,024 7,769 255 10,840 
APPENDIX F 

Page 1 of 2

SELECTED PHARMACIES’ AVERAGE PART D DISPENSING FEES 

Sample 

Item 

Average 

Dispensing 

Fee for All 

Drugs 

Average 

Dispensing 

Fee for 

BrandName 

Drugs 

Average 

Dispensing 

Fee for 

Generic 

Drugs 

Sample 

Item 

Average 

Dispensing 

Fee for All 

Drugs 

Average 

Dispensing 

Fee for 

BrandName 

Drugs 

Average 

Dispensing 

Fee for 

Generic 

Drugs 

 30 $4.84 $2.68 $5.41 70 $2.09 $1.92 $2.20 

29 3.93 3.89 4.00 39 2.08 1.88 2.19 

4 3.88 3.35 4.06 77 2.05 2.08 2.04 

93 3.87 3.79 3.93 95 2.05 1.82 2.15 

74 3.66 3.28 3.90 3 2.04 1.83 2.26 

87 3.50 3.21 3.62 16 2.04 1.95 2.14 

48 3.44 2.85 3.67 47 2.04 2.00 2.08 

76 3.38 3.29 3.53 69 2.03 1.96 2.05 

2 3.34 3.61 3.21 7 2.01 1.92 2.07 

6 3.25 3.06 3.38 86 2.01 1.77 2.11 

10 3.23 3.00 3.43 78 2.00 1.75 2.14 

1 3.21 2.92 3.36 94 2.00 2.00 2.00 

8 3.16 2.91 3.35 14 1.99 1.84 2.06 

37 3.03 3.32 2.71 51 1.97 1.91 2.02 

17 2.93 2.18 3.57 75 1.97 1.92 2.00 

66 2.85 2.67 2.94 53 1.96 1.75 2.08 

35 2.82 2.67 2.91 55 1.96 1.88 2.00 

84 2.78 2.62 2.86 82 1.96 1.91 2.02 

41 2.75 2.74 2.76 20 1.95 1.89 2.00 

72 2.72 2.29 2.99 90 1.95 1.86 2.00 

54 2.67 3.00 2.00 34 1.93 1.86 1.97 

80 2.58 2.34 2.69 67 1.93 1.87 1.98 

99 2.50 2.38 2.58 96 1.93 1.74 2.13 

22 2.49 2.39 2.54 71 1.92 1.76 2.05 

43 2.45 2.24 2.54 27 1.91 1.93 1.91 

73 2.43 2.08 2.58 45 1.91 1.86 1.96 

18 2.40 2.20 2.49 62 1.89 1.76 2.10 

42 2.39 2.29 2.50 83 1.89 1.71 2.00 

92 2.39 2.20 2.48 97 1.89 1.68 2.01 

24 2.37 2.26 2.50 23 1.88 1.70 2.08 

88 2.36 2.01 2.49 57 1.88 1.70 2.02 

12 2.33 2.02 2.50 61 1.87 1.69 2.00 

15 2.31 2.21 2.35 13 1.86 1.60 2.06 

59 2.31 2.23 2.35 21 1.86 1.67 2.06 

36 2.29 2.25 2.33 40 1.86 1.65 2.01 

9 2.27 2.00 2.35 19 1.85 1.65 1.97 

58 2.27 2.22 2.32 33 1.85 1.50 2.00 

60 2.26 1.96 2.44 31 1.84 1.61 1.93 

85 2.25 1.89 2.32 52 1.84 1.67 1.93 

49 2.22 2.19 2.26 28 1.83 1.65 2.00 

64 2.14 2.33 2.04 50 1.83 1.63 1.99 
APPENDIX F 

Page 2 of 2 

Sample 

Item 

Average 

Dispensing 

Fee for All 

Drugs 

Average 

Dispensing 

Fee for 

BrandName 

Drugs 

Average 

Dispensing 

Fee for 

Generic 

Drugs 

79 $1.83 $1.78 $1.87 

68 1.82 1.50 2.00 

65 1.81 1.78 1.84 

25 1.80 1.75 1.83 

38 1.79 1.59 2.02 

44 1.78 1.75 1.79 

89 1.78 1.72 1.83 

11 1.77 1.68 1.88 

5 1.76 1.61 1.98 

56 1.74 1.75 1.73 

91 1.72 1.66 1.79 

32 1.70 1.61 1.75 

98 1.70 1.79 1.62 

63 1.67 1.52 1.79 

46 1.49 1.49 1.49 

81 1.41 1.50 1.38 

26 1.40 1.28 1.50 
APPENDIX G 

Page 1 of 2 
APPENDIX G 

Page 2 of 2