PRESCRIPTION 

DRUGS

Comparison of DOD 

and VA Direct 

Purchase Prices

Report to the Ranking Member, 

Committee on Homeland Security and 

Governmental Affairs, U.S. Senate

April 2013

GAO-13-358

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-13-358, a report to the 

Ranking Member, Committee on Homeland 

Security and Governmental Affairs, U.S. 

Senate

April 2013

PRESCRIPTION DRUGS

Comparison of DOD and VA Direct Purchase Prices

Why GAO Did This Study

In fiscal year 2012, DOD and VA spent 

a combined $11.8 billion to purchase 

drugs on behalf of about 18.5 million 

beneficiaries. Both agencies purchase 

drugs directly from manufacturers via 

prime vendors—intermediaries that 

provide the drugs at a discount off the 

lowest price that would otherwise be 

available. The agencies dispense 

these drugs to beneficiaries through 

their medical facilities and pharmacies, 

including their mail order pharmacies. 

GAO was asked to compare prices 

paid for prescription drugs across 

federal programs. This report 

describes direct purchase prices paid 

by DOD and VA for a sample of 

prescription drugs. GAO will compare 

drug prices paid using other 

approaches and by other federal 

programs in future work. Using prime 

vendor data provided by these 

agencies for the first quarter of 2012, 

GAO selected a sample of highutilization and high-expenditure drugs 

important to both DOD and VA and 

compared average unit prices paid by 

these agencies for those drugs. The 

sample contained 43 brand-name and 

40 generic drugs and accounted for 37 

percent of DOD utilization, 32 percent 

of DOD expenditures, 28 percent of VA 

utilization, and 35 percent of VA 

expenditures for directly purchased 

drugs in that quarter. GAO calculated 

average unit prices by dividing total 

expenditures by total utilization for 

each drug, the entire sample, and the 

subsets of brand-name and generic 

drugs. GAO also compared DOD and 

VA average unit prices to the FSS and 

Big Four prices for each drug. GAO 

interviewed DOD and VA officials 

about their drug purchasing 

approaches and factors affecting the 

prices they are able to obtain. 

What GAO Found

When GAO compared prices paid by the Department of Defense (DOD) and the 

Department of Veterans Affairs (VA) for a sample of 83 drugs purchased in the 

first calendar quarter of 2012, DOD’s average unit price for the entire sample was 

31.8 percent ($0.11 per unit) higher than VA’s average price, and DOD’s average 

unit price for the subset of 40 generic drugs was 66.6 percent ($0.04 per unit) 

higher than VA’s average price. However, VA’s average unit price for the subset 

of 43 brand-name drugs was 136.9 percent ($1.01 per unit) higher than DOD’s 

average price. These results were consistent with each agency obtaining better 

prices on the type of drugs that made up the majority of its utilization: generic 

drugs accounted for 83 percent of VA’s utilization of the sample drugs and brandname drugs accounted for 54 percent of DOD’s utilization of the sample drugs. 

DOD officials told GAO that in certain circumstances they are able to obtain 

competitive prices for brand-name drugs—even below the prices for generic 

equivalents—and therefore will often preferentially purchase brand-name drugs. 

At the individual drug level, DOD paid higher average unit prices than VA for 32 

of the 40 generic drugs and for 23 of the 43 brand-name drugs in the sample, 

while VA paid higher average unit prices for the remaining 8 generic drugs and 

20 brand-name drugs. In nearly every case, substantially higher prices paid by 

one agency were correlated with substantially lower utilization by that agency. 

Specifically, for 10 of the 11 drugs for which one agency paid more than 

100 percent above the price paid by the other agency, the agency that paid a 

substantially higher price also had substantially lower utilization. However, even 

when one agency paid a substantially higher price than the other, in all 11 cases 

both agencies paid less than the highest of the Federal Supply Schedule (FSS) 

prices available to all direct federal purchasers or the Big Four prices available to 

the four largest government purchasers. Additionally, in most cases (9 out of 11 

drugs) both agencies paid less than the lowest of these prices. The lower prices 

obtained by one agency may be due to factors such as differences in the 

agencies’ formulary design and prescription practices, price and rebate 

negotiations with manufacturers that may not be available more broadly to the 

other agency, and differences in utilization practices between the agencies based 

on differences in their beneficiary populations.

DOD and VA face continued challenges in controlling drug costs. While the 

prescription drug market is complex and there are many factors affecting the 

prices DOD and VA are able to obtain for directly purchased drugs, differences in 

prices paid for specific drugs may provide insights into opportunities for each 

agency to obtain additional savings on at least some of the drugs they purchase. 

In commenting on a draft of this report, DOD generally agreed with GAO’s 

findings and described additional factors that may contribute to differences in 

prices paid by DOD and VA. VA expressed concerns with the content of the 

report. VA suggested additional analyses and highlighted the impact of program 

design on each agency’s use of prescription drugs. GAO maintains that its 

analyses have value in identifying opportunities for savings and the report 

acknowledges the limitations involved with estimating potential cost savings in 

this complex area. DOD and VA also provided technical comments that GAO 

incorporated as appropriate.

View GAO-13-358. For more information, 

contact John E. Dicken at (202) 512-7114 or 

dickenj@gao.gov.
Page i GAO-13-358 DOD and VA Direct Purchase Drug Prices

Letter 1 

Background 3

DOD Paid a Higher Average Direct Purchase Price Than VA across 

the Entire Sample but Paid Less Than VA for Brand-Name Drugs 6

Concluding Observations 10

Agency Comments and Our Evaluation 11

Appendix I Scope and Methodology 14

Appendix II Relative Prices Paid by DOD and VA for the 83 Drugs 

in the Direct Purchase Sample 22

Appendix III Comments from the Department of Defense 25

Appendix IV Comments from the Department of Veterans Affairs 27

Appendix V GAO Contact and Staff Acknowledgments 29

Related GAO Products 30

Table

Table 1: Direct Purchase Drug Sample, First Calendar Quarter of 

2012 17

Figures

Figure 1: DOD and VA Relative Average Unit Prices for Drugs in 

the Sample, First Quarter of 2012 7

Figure 2: Number of Drugs in the Sample for Which DOD or VA 

Paid the Higher Average Unit Price, First Quarter of 2012 8

Contents 
Page ii GAO-13-358 DOD and VA Direct Purchase Drug Prices

Figure 3: Drugs for Which DOD Paid a Higher Average Unit Price 

Than VA, First Calendar Quarter of 2012 23

Figure 4: Drugs for Which VA Paid a Higher Average Unit Price 

Than DOD, First Calendar Quarter of 2012 24

Abbreviations

CMOP Consolidated Mail Outpatient Pharmacy

DOD Department of Defense

FSS Federal Supply Schedule

HCPCS Healthcare Common Procedure Coding System 

MTF military treatment facility

NCPDP National Council for Prescription Drug Programs

NDA new drug application

NDC national drug code

TMOP TRICARE Mail Order Pharmacy

VA Department of Veterans Affairs

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Page 1 GAO-13-358 DOD and VA Direct Purchase Drug Prices

United States Government Accountability Office

Washington, DC 20548

April 19, 2013

The Honorable Tom Coburn, M.D.

Ranking Member

Committee on Homeland Security and Governmental Affairs

United States Senate

Dear Dr. Coburn:

The Department of Defense (DOD) and Department of Veterans Affairs 

(VA) are major federal purchasers of prescription drugs. In fiscal year 

2012, the departments spent a combined $11.8 billion to purchase drugs 

on behalf of approximately 18.5 million beneficiaries.1 In fiscal year 2011, 

the departments’ expenditures—totaling about $11.3 billion—amounted to 

about 13 percent of all federal drug expenditures.2 As we previously 

reported, DOD and VA face continued challenges in controlling drug costs 

and need to make drug savings a priority.3

One method used by DOD and VA to pay for prescription drugs on behalf 

of their beneficiaries is the direct purchase approach. In this approach, 

the program purchases drugs directly from manufacturers—through 

intermediaries known as prime vendors4

 

1

Total DOD and VA spending includes all VA drug expenditures plus DOD’s expenditures 

for drugs dispensed at DOD inpatient and clinic facilities as well as all outpatient 

prescriptions filled at the TRICARE Mail Order Pharmacy (TMOP), DOD pharmacies, and 

non-DOD retail pharmacies. DOD officials told us they are unable to provide spending 

totals for inpatient drugs in non-DOD facilities because costs for these drugs are usually 

bundled with other services for payment.

—and dispenses them to 

2

Total federal prescription drug expenditures for 2011 were obtained from the National 

Health Expenditures data for 2011 (the most recent comprehensive federal data available 

at the time of our analysis) and include spending for DOD, VA, Medicare, Medicaid, the 

Children’s Health Insurance Program, Indian Health Services, and Maternal/Child Health. 

See Centers for Medicare & Medicaid Services, Office of the Actuary, Division of Health 

Statistics, NHE Web Tables, accessed January 17, 2013, http://www.cms.gov/ResearchStatistics-Data-and-Systems/Statistics-Trends-andReports/NationalHealthExpendData/NationalHealthAccountsHistorical.html. 

3

See GAO, Opportunities to Reduce Potential Duplication in Government Programs, Save 

Tax Dollars, and Enhance Revenue, GAO-11-318SP (Washington, D.C.: March 1, 2011), 

pp. 82-87.

4

Both DOD and VA use a competitive bidding process to award contracts to one or more 

prime vendors for the purchase and delivery of drugs to the agencies’ facilities.

 
 

Page 2 GAO-13-358 DOD and VA Direct Purchase Drug Prices

beneficiaries through their own medical facilities and pharmacies.5 DOD 

and VA have access to certain federal pricing arrangements for these 

direct purchases, including Federal Supply Schedule (FSS) prices—

prices available to all direct federal purchasers—and Big Four prices—

prices available to the four largest federal purchasers.6

You requested that we compare prices paid for prescription drugs across 

federal programs. In this report, we describe direct purchase prices paid 

by DOD and VA for a sample of prescription drugs. We will compare drug 

prices paid using other approaches and by other federal programs 

including Medicare and Medicaid in future work.

In addition, the 

prime vendors used by DOD and VA for these purchases provide a fixed 

percentage discount off the lowest price (e.g., the FSS or Big Four price) 

otherwise available for each drug. Direct purchase drug prices are 

generally not subject to intermediary markups from a wholesaler or other 

distributor.

In order to compare direct purchase prices paid by DOD and VA for a 

sample of prescription drugs, we selected a sample of drugs important to 

both agencies and compared unit prices paid by each agency for those 

drugs. The sample included the top 50 brand-name and top 50 generic 

drugs based on combined utilization ranks and combined expenditure 

ranks for DOD and VA in the first calendar quarter of 2012.7

 

5

Other purchasing approaches include retail reimbursement, in which DOD allows its 

beneficiaries to fill prescriptions in non-DOD retail pharmacies and then reimburses the 

pharmacies for the cost of the drugs. In some cases, VA beneficiaries can obtain drugs on 

a fee-for-service basis through non-VA facilities. The retail reimbursement and fee-forservice payment approaches are outside the scope of this report.

After 

accounting for overlap between the high-utilization and high-expenditure 

drugs, the final sample contained 43 brand-name drugs and 40 generic 

drugs and included 37.0 percent of DOD utilization, 31.7 percent of DOD 

expenditures, 27.7 percent of VA utilization, and 34.8 percent of VA 

6

Big Four prices are available to DOD, VA, the Public Health Service, and the U.S. Coast 

Guard.

7

A brand-name drug is a drug marketed under a proprietary, trademark-protected name. 

After any patent and market exclusivity for the brand-name drug expires, other drug 

companies may develop a generic equivalent—a similar drug that has the same active 

ingredient, strength, dosage form, route of administration, and intended use. We excluded

physician-administered outpatient prescription drugs and over-the-counter drugs from our 

sample. We also excluded items that are not traditionally considered drugs such as 

bandages, syringes, needles, diabetes test strips, saline, and water for irrigation. 
 

Page 3 GAO-13-358 DOD and VA Direct Purchase Drug Prices

expenditures for directly purchased prescription drugs. We calculated 

average unit prices paid by DOD and VA by dividing total expenditures by 

total utilization for: each drug; the entire sample; the subset of brandname drugs; and the subset of generic drugs. In order to maintain the 

confidentiality of prices for individual drugs, in each case we converted 

from absolute prices to relative prices by assigning 100.0 to the lowest 

price and determining the higher price as a percentage above the lowest 

price. We compared the average unit prices paid by DOD and VA to the 

FSS and Big Four prices available to these agencies. Finally, we 

determined the maximum potential savings that might have been 

obtained if each agency had been able to obtain the lower of the DOD 

and VA average unit prices for each of the 83 drugs in the sample. The 

results of our analyses are limited to the 83 high-utilization and highexpenditure drugs in our sample for the first calendar quarter of 2012 and 

are not necessarily applicable across all drugs. We also interviewed DOD 

and VA officials about drug purchasing approaches they use and factors 

affecting the prices they are able to obtain. See appendix I for additional 

details on our methodology and a list of the drugs in the sample. See the 

Related GAO Products list for other GAO work on DOD and VA drug 

programs.

Data were received from DOD in June 2012 and from VA in July 2012. 

We reviewed agency data for reasonableness and consistency, including 

screening for outlier prices and examining possible reasons for 

inconsistencies between the data sources. We also reviewed 

documentation and talked to data providers about steps they take to 

ensure data reliability, but did not confirm the accuracy of the underlying 

data. We conducted this performance audit from April 2012 through April

2013 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

In fiscal year 2012, VA provided prescription drug coverage to about 

8.8 million eligible veterans primarily through its medical centers and Background 
 

Page 4 GAO-13-358 DOD and VA Direct Purchase Drug Prices

Consolidated Mail Outpatient Pharmacy (CMOP).8

• Federal Supply Schedule (FSS) prices: These prices are available to 

all direct federal purchasers and are intended to be no more than the 

prices manufacturers charge their most-favored nonfederal customers 

under comparable terms and conditions.

VA primarily uses the 

direct purchase approach to acquire drugs directly from manufacturers for 

distribution through its facilities. These purchases are usually made under 

contract with a prime vendor that provides the drugs at a fixed percentage 

discount off the lowest price otherwise available for each drug. VA’s drug 

prices are generally below wholesale prices provided to commercial 

buyers and do not include costs for storage, overhead, or dispensing. VA 

also has access to federal pricing arrangements and other discounts to 

help control drug spending, including the following:

• Big Four prices: These prices are available to DOD, VA, the Public 

Health Service, and the U.S. Coast Guard. By law, these prices are 

24 percent lower than nonfederal average manufacturer prices.9

• VA national contracts: These contracts provide additional pricing 

concessions in return for commitment to potential vendors, resulting in 

pricing lower than FSS. The VA national contracts program is a 

separate contract vehicle from the FSS contract program.10

In fiscal year 2012, VA’s prescription drug spending totaled about 

$4.2 billion, according to VA officials.11

 

8

Veterans who served in active military duty and who were discharged or released under 

conditions other than dishonorable are generally eligible for VA health care. Reservists, 

National Guard members, and certain others may also be eligible for VA health care under 

certain conditions. In some cases, VA beneficiaries can obtain drugs on a fee-for-service 

basis through non-VA facilities. These make up a very small proportion of VA drug 

expenditures (less than 1 percent in fiscal year 2010) and are outside the scope of this 

report.

9

See 38 U.S.C. § 8126(a)(2). The nonfederal average manufacturer price is the weighted 

average price of a single form and dosage unit paid by wholesalers to a manufacturer, 

taking into account cash discounts or similar price reductions. Big Four prices, in general, 

do not apply to generic drugs.

10In fiscal year 2012, VA’s national contract purchases totaled $296.8 million, or about 

6 percent of total drug expenditures.

11Spending is net of beneficiary copayments.
 

Page 5 GAO-13-358 DOD and VA Direct Purchase Drug Prices

In fiscal year 2012, DOD provided prescription drug coverage to about 

9.7 million active-duty and retired military personnel, their dependents, 

and others through its military treatment facilities (MTF), the TRICARE 

Mail Order Pharmacy (TMOP), and retail pharmacies.12 As with VA, DOD 

has access to FSS and Big Four prices and uses the direct purchase 

approach to buy drugs at a discount through a prime vendor for 

distribution through its MTFs and TMOP. Therefore, DOD’s direct 

purchase drug prices are also generally below wholesale prices provided 

to commercial buyers and do not include costs for storage, overhead, or 

dispensing.13 In fiscal year 2012, DOD’s prescription drug spending 

totaled about $7.6 billion, according to DOD officials.14

Both DOD and VA use prescription drug formularies to help control 

prescription drug costs.15 In our November 2012 report on DOD and VA

health care, agency officials told us that some of the differences in the 

agencies’ formularies are due to differences in the structure of their health 

care systems.16 For example, DOD covers prescriptions written by both 

military and civilian providers, and DOD officials previously reported that, 

as a result, the department needs to have a broad formulary to account 

for differences in prescribing practices among different providers.17

 

12Other beneficiaries include National Guard and Reserve members, their families, 

survivors, and certain former spouses worldwide. TRICARE is a regionally structured 

program that uses contractors to maintain provider networks to complement health care 

provided at MTFs. Prescriptions filled by DOD beneficiaries at retail pharmacies are 

excluded from this report because they are not directly purchased by DOD.

In 

13However, DOD officials told us that direct purchase prices for drugs shipped to DOD 

facilities overseas include a shipping charge and therefore the prime vendor prices for 

these purchases will be slightly above the actual cost of the drug.

14Spending is net of beneficiary copayments and postpurchase refunds and includes 

drugs dispensed at DOD inpatient and clinic facilities as well as all outpatient prescriptions 

filled through TMOP, DOD pharmacies, and non-DOD retail pharmacies. Of the $7.6 

billion, about $3.9 billion (51 percent) was for directly purchased drugs. 

15See GAO, Prescription Drugs: Overview of Approaches to Control Prescription Drug 

Spending in Federal Programs, GAO-09-819T (Washington, D.C.: June 24, 2009), p. 9. A 

formulary is a list of medications, grouped by therapeutic class, that a health care 

system’s providers are expected to use when prescribing medications. 

16See GAO, DOD and VA Health Care: Medication Needs during Transitions May Not Be 

Managed for All Servicemembers, GAO-13-26 (Washington, D.C.: Nov. 2, 2012), p. 36.

17With the exception of several classes such as smoking-cessation and weight-loss 

medications, DOD makes all Food and Drug Administration–approved medications 

available.
 

Page 6 GAO-13-358 DOD and VA Direct Purchase Drug Prices

contrast, VA primarily covers medications for eligible beneficiaries 

through prescriptions written by its own providers. As VA officials 

reported, this allows VA to have more direct control over the medications 

that are prescribed to its patient population. Both agencies provide 

access to nonformulary medications determined by a physician to be 

clinically necessary.

DOD paid a higher average unit price than VA across the entire sample of 

83 drugs and for the subset of generic drugs, but paid a lower average 

price than VA for the subset of brand-name drugs. Specifically, DOD’s 

average unit price for the entire sample was 31.8 percent higher than 

VA’s average price, and DOD’s average unit price for the subset of 40 

generic drugs was 66.6 percent higher than VA’s average price. However, 

VA’s average unit price for the subset of 43 brand-name drugs was 

136.9 percent higher than DOD’s average price. (See fig. 1.) DOD paid 

an average of $0.11 per unit more than VA across the entire sample of 

83 drugs and an average of $0.04 per unit more than VA for the generic 

drugs in our sample, while VA paid an average of $1.01 per unit more 

than DOD for the brand-name drugs in our sample.18

 

18DOD’s average unit price (e.g., price per tablet, capsule, or milliliter) for the entire 

sample of 83 drugs was $0.45 while VA’s corresponding unit price was $0.34. For the 

subset of generic drugs, DOD’s average unit price was $0.10 while VA’s corresponding 

unit price was $0.06. DOD’s average unit price for the subset of brand-name drugs was 

$0.74 while VA’s corresponding unit price was $1.75.

These results were 

consistent with each agency obtaining better prices on the type of drugs 

that made up the majority of its utilization: generic drugs accounted for 

the majority (83 percent) of VA’s utilization of drugs in the sample for the 

first quarter of 2012, and brand-name drugs accounted for the majority 

(54 percent) of DOD’s utilization of the sample drugs during the same 

period. DOD officials told us that in certain circumstances they are able to 

obtain competitive prices for brand-name drugs—even below the prices 

DOD Paid a Higher 

Average Direct 

Purchase Price Than 

VA across the Entire 

Sample but Paid Less 

Than VA for BrandName Drugs
 

Page 7 GAO-13-358 DOD and VA Direct Purchase Drug Prices

for generic equivalents—and therefore will often preferentially purchase 

brand-name drugs.19

Figure 1: DOD and VA Relative Average Unit Prices for Drugs in the Sample, First 

Quarter of 2012

Note: The Truven Health Analytics data used were Red Book data.

When we examined the prices paid for the individual brand-name drugs in 

our sample, DOD paid higher average unit prices than VA for 23 of the 

 

19For example, DOD is often able to obtain competitive prices for brand-name drugs 

during the period when the generic equivalents are beginning to come to market. This was 

the case for Lipitor, which DOD was able to obtain at a price below its generic equivalent 

for several months after the first generic equivalent came on the market. In other 

instances, DOD is able to obtain significant price reductions for single-source brand-name 

drugs (i.e., drugs for which there is no generic equivalent) within a therapeutic class that 

includes other generic competitors. For example, DOD was able to obtain significant price 

reductions for Nexium because this drug is in a therapeutic class containing several other 

brand-name and generic drugs.
 

Page 8 GAO-13-358 DOD and VA Direct Purchase Drug Prices

43 drugs (see fig. 2).20

Figure 2: Number of Drugs in the Sample for Which DOD or VA Paid the Higher 

Average Unit Price, First Quarter of 2012

VA paid higher average unit prices for the 

remaining 20 brand-name drugs. DOD also paid a higher average price 

than VA for a majority of the generic drugs in our sample. Specifically, 

DOD paid a higher price for 32 of the 40 generic drugs in our sample, 

while VA paid a higher average price for the remaining 8 generic drugs. 

(See app. II for details on the relative prices paid by DOD and VA for the 

83 individual drugs in our sample.)

Notes: Of the 23 brand-name drugs for which DOD paid a higher price, 8 were different strengths of 

the same brand-name drug (Synthroid). The Truven Health Analytics data used were Red Book data.

 

20However, 8 of these 23 drugs were different strengths of the same brand-name drug: 

Synthroid, a thyroid supplement.
 

Page 9 GAO-13-358 DOD and VA Direct Purchase Drug Prices

In nearly every case, substantially higher prices paid by one agency were 

correlated with substantially lower utilization by that agency. Specifically, 

we found 11 drugs for which one agency paid more than 100 percent 

above the price paid by the other agency. For 10 of these drugs, the 

agency that paid a substantially higher price also had substantially lower 

utilization.21 This may indicate that prices can vary based on the relative 

importance of a drug to a given agency. However, it is noteworthy that 

even when one agency paid a substantially higher price than the other, in 

all 11 cases both agencies paid less than the highest of the FSS or Big 

Four prices available to government purchasers of the drug, and in most 

cases (9 out of 11 drugs) both agencies paid less than the lowest of the 

FSS or Big Four prices.22

If DOD and VA had each been able to obtain the lowest of DOD’s or VA’s 

average unit price for each of the 83 drugs in the sample, the maximum 

potential savings for DOD would have been about $19.1 million 

(7.5 percent of DOD’s spending for the drugs in the sample) in the first 

quarter of 2012 and the maximum potential savings for VA would have 

been about $13.9 million (5.1 percent of VA’s spending on the drugs in 

the sample) during that same period. However, it is unlikely that this 

magnitude of savings could be achieved in practice because of the 

complexity of the prescription drug market and factors that affect the 

prices DOD and VA are able to obtain for drugs. For example, these 

savings apply only to the 83 drugs in our sample in the quantities 

purchased during the first quarter of 2012 and may not be representative 

of the savings available across all drugs in various calendar quarters. If 

either agency had purchased different drugs or even different quantities 

of the same drugs, the maximum potential savings could have been 

markedly different. Additionally, the lower prices obtained by one agency 

may be due to factors such as

 

21For example, VA paid 502.5 percent more than DOD, on average, for 40 mg delayed 

release capsules of Nexium. This drug was the third highest utilization brand-name drug 

for DOD (which purchased more than 26 million capsules) but only the 97th highest 

utilization brand-name drug for VA (which purchased fewer than 1 million capsules).

22A given drug corresponds to one or more national drug codes (NDC), each representing 

a different labeler or different package size. Each NDC may have an FSS price and a Big 

Four price available to government purchasers, so there may be many such prices 

corresponding to a given drug. We compared the average unit prices paid by DOD and VA 

for each drug to all FSS and Big Four prices corresponding to the drug.
 

Page 10 GAO-13-358 DOD and VA Direct Purchase Drug Prices

• differences in the agencies’ formulary designs and prescription 

practices—for example, DOD’s broader formulary, designed to 

accommodate prescriptions written by non-DOD providers, and VA’s 

greater control over prescribing, designed to allow it to steer utilization 

toward a limited number of drugs within a given therapeutic class;

23

• differences in utilization practices between the agencies based on 

differences in their beneficiary populations;24

• price and rebate negotiations with manufacturers that may not be 

available more broadly to the other agency—as VA officials told us, 

these can include VA’s national purchase contracts or temporary price 

reductions offered to VA by a manufacturer in order to increase a 

drug’s market share;

• differences between the discounts obtained from one agency’s prime 

vendors through a competitive bidding process and potentially not 

available to the other agency;25

• drug shortages—DOD officials told us that insufficient quantities of 

less expensive versions of a drug may force an agency to purchase a 

more expensive version; or

• other factors, such as differences in purchasing authority, that may 

limit the extent to which particular discounts provided to one agency 

are available to the other agency.

DOD and VA face continued challenges in controlling drug costs. Our 

findings suggest that there may be opportunities for savings with directly 

purchased drugs. DOD and VA paid different prices for the drugs in our 

sample; for 11 of the 83 drugs, one agency paid at least 100 percent 

more than the other agency. DOD paid a lower average price for the 

brand-name drugs in our sample while VA paid less, on average, for the 

 

23For additional information on DOD and VA formulary design, see GAO-13-26. 

24See Congressional Budget Office, The Department of Veterans Affairs’ Pharmaceutical 

Prime Vendor Program (Washington, D.C.: Feb. 25, 2009), p. 1.

25For additional information on the DOD and VA prime vendor programs, see 

Congressional Budget Office, The Prime Vendor Program. 

Concluding 

Observations 
 

Page 11 GAO-13-358 DOD and VA Direct Purchase Drug Prices

generic drugs and across the entire sample. Our past reports highlight the 

importance of DOD and VA controlling drug costs. While the prescription 

drug market is complex and there are many factors affecting the prices 

DOD and VA are able to obtain for directly purchased drugs, differences 

in prices paid for specific drugs may provide insights into opportunities for 

each agency to obtain additional savings on at least some of the drugs 

they purchase.

DOD and VA reviewed a draft of this report and provided written 

comments, which are reprinted in appendixes III and IV, respectively. 

DOD generally agreed with our methodology and findings. In addition, 

DOD noted that expressing differences between DOD and VA prices for 

the sample as percentages rather than actual dollar amounts may give 

the impression that significant dollar values are involved rather than a few 

cents or less per unit. While we clarified in the report the dollar amount of 

price differences, our findings indicated that small per-unit price 

differences may result in significant additional expenditures when 

accounting for the quantities purchased by the agencies. DOD also 

described additional factors beyond those mentioned in our findings that 

may contribute to differences in prices paid by DOD and VA.

VA expressed concerns with the content of the report and suggested 

additional analyses. For example, VA suggested that analyses accounting 

for per-beneficiary costs, formulary design, utilization management, and 

the mix of drugs used for a particular disease state would have provided 

more appropriate comparisons. While we agree that such analyses could 

be useful, the scope of our work was targeted to a comparison of prices 

paid by each agency for a sample of high-utilization and high-expenditure 

drugs and was not intended to capture all factors that can affect 

pharmaceutical spending. We noted the limitations of our results in the 

report, including that our results cannot be applied to all drugs purchased 

by the agencies. Further, our report acknowledges the limitations involved 

with estimating potential cost savings in this complex area. Nonetheless, 

we maintain that comparing unit prices paid for selected generic and 

brand-name drugs by different federal agencies has value in identifying 

specific drugs with price differences that may warrant further 

consideration for potential savings.

Agency Comments 

and Our Evaluation
 

Page 12 GAO-13-358 DOD and VA Direct Purchase Drug Prices

VA also noted that most of its drug purchases are made through contracts 

with a prime vendor that provides a negative distribution fee (i.e., 

discount), resulting in savings to VA. We revised the introduction to make 

this information more prominent earlier in the report. VA agreed with our 

conclusion that the maximum potential savings provided in our findings 

are unlikely to be achieved and noted that obtaining lower prices on 

brand-name drugs would require shifting utilization away from generic 

drugs, potentially increasing overall drug costs. VA also stated that our list 

of factors affecting the prices each agency is able to obtain did not 

specifically include the ability of VA to direct utilization toward a limited 

number of drugs within a therapeutic class to achieve savings. We 

revised the report to clarify this point.

VA also stated that, under an applicable Federal Acquisition Regulation 

(48 C.F.R. § 8.002), it was required to purchase more expensive versions 

of generic minocycline through the FSS contract rather than versions 

otherwise available. VA therefore requested that GAO remove the 

potential savings related to the purchase of this drug from the total 

projected savings in the report. However, our report generally reflects a 

number of factors (including differences in purchasing authority) that may 

limit each agency’s ability to achieve the maximum potential savings we 

calculated, and it was beyond the scope of our report to apply these 

factors to each individual drug.

DOD and VA also provided technical comments, which we incorporated 

as appropriate.

As agreed with your office, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies of this report to relevant 

congressional committees and other interested members. The report also 

will be available at no charge on the GAO website at http://www.gao.gov. 
 

Page 13 GAO-13-358 DOD and VA Direct Purchase Drug Prices

If you or your staff have any questions regarding this report, please 

contact me at (202) 512-7114 or dickenj@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. GAO staff members who made key 

contributions to this report are listed in appendix V. 

Sincerely yours,

John E. Dicken

Director, Health Care
Appendix I: Scope and Methodology

Page 14 GAO-13-358 DOD and VA Direct Purchase Drug Prices

In order to compare direct purchase prices paid by the Department of 

Defense (DOD) and Department of Veterans Affairs (VA) for prescription 

drugs, we chose a sample of drugs important to both agencies. We 

obtained prime vendor data for the first calendar quarter of 2012 for drugs 

dispensed to DOD and VA beneficiaries through the agencies’ own 

medical facilities and mail order pharmacies.1 We excluded physicianadministered outpatient prescription drugs and over-the-counter drugs 

from our sample; we also excluded items that are not traditionally 

considered drugs such as bandages, syringes, needles, diabetes test 

strips, saline, and water for irrigation.2 We used data from Red Book to 

determine the brand-name or generic status of each drug.3 Utilization was 

determined using the National Council for Prescription Drug Programs 

(NCPDP) Billing Unit Standard.4

 

1

Direct purchases of drugs by DOD and VA are usually made under contract with one or 

more intermediaries, known as prime vendors, which agree to provide drugs at a fixed 

percentage discount off the lowest price otherwise available for each drug.

When calculating expenditures, we used 

the agencies’ costs to purchase each drug without accounting for any 

2

Because Medicare Part B primarily covers physician-administered outpatient drugs, we 

used Part B data to identify and exclude these drugs from our sample. However, Medicare 

Part B uses Healthcare Common Procedure Coding System (HCPCS) codes to identify 

drugs while DOD and VA use national drug codes (NDC). Therefore, we used the January 

2012 NDC-HCPCS Crosswalk Files for Medicare Part B to identify physician-administered 

drugs in the DOD and VA samples so we could exclude them.

3

Red Book is a drug pricing compendium with information about prices and other 

characteristics of drug products, published by Truven Health Analytics. A brand-name 

drug is a drug marketed under a proprietary, trademark-protected name. After any patent 

and market exclusivity for the brand-name drug expires, other drug companies may 

develop a generic equivalent—a similar drug that has the same active ingredient, strength, 

dosage form, route of administration, and intended use. Red Book identified two drugs in

our sample (Klor-Con 10 and Thermazene) as “branded-generic” drugs. To determine 

whether to group these drugs with the brand-name subset or the generic subset, we 

identified the type of drug application submitted by the manufacturer for original Food and 

Drug Administration approval. Both drugs were originally approved using a new drug 

application (NDA). Because manufacturers typically submit an NDA when seeking 

approval for brand-name drugs, we grouped these two drugs with the other brand-name 

drugs in our sample.

4

NCPDP developed the Billing Unit Standard to assist in consistent and accurate billing of 

pharmaceutical products and to standardize the reporting of units to the Centers for 

Medicare & Medicaid Services for rebate purposes. Generally, these standards report 

items in one of three units: each (when a product is measured in discrete units such as 

tablets, capsules, vials, or kits), milliliters (when a product is measured in liquid volume), 

and grams (when a product is measured by weight). The use of these standards may 

cause certain drugs (e.g., liquids) to have a higher utilization rank than they would if a 

different method had been used.

Appendix I: Scope and Methodology
Appendix I: Scope and Methodology

Page 15 GAO-13-358 DOD and VA Direct Purchase Drug Prices

future offsets from beneficiary copayments for those drugs.5 We 

aggregated the utilization and expenditure data at the drug level (drug 

name, strength, and dosage form) separately for DOD and VA. For 

example, all national drug codes (NDC) corresponding to 10 mg tablets of 

Lipitor purchased by VA were aggregated and the associated utilization 

and expenditures were summed and compared to other brand-name 

drugs, while NDCs corresponding to 10 mg tablets of atorvastatin (the 

generic equivalent of Lipitor) purchased by VA were aggregated 

separately and compared to other generic drugs.6

We ranked the top 100 brand-name and top 100 generic drugs separately 

for each agency on the basis of utilization and expenditures and then 

combined these rankings to determine the top brand-name and generic 

drugs that were purchased by both agencies. We excluded drugs that 

were in the top 100 for one agency but not for the other agency in order to 

focus our analysis on drugs that were important for both DOD and VA. 

For example, if a drug was 10th highest in utilization for VA but was not in 

the top 100 for DOD, that drug would not be included in our sample. 

Some drugs that were excluded from the sample appeared to be more 

appropriate for the beneficiary population of one agency than the other. 

For example, primaquine phosphate—a drug used to treat malaria—was 

the fourth-highest-expenditure generic drug for DOD but was not in the 

top 100 for VA. Some other excluded drugs were additional strengths of 

drugs that did appear in our sample. For example, simvastatin (80 mg 

tablet) was the sixth-highest-expenditure generic drug for VA but was not 

in the top 100 for DOD and thus was excluded from the sample. However, 

the 20 mg and 40 mg strengths of simvastatin were included in the 

sample.

 

5

DOD officials told us that direct purchase prices for drugs shipped to DOD facilities 

overseas include a shipping charge and therefore the prime vendor prices for these 

purchases will be slightly above the actual cost of the drug.

6

NDCs are three-segment numbers that are the universal product identifiers for drugs for 

human use. The Food and Drug Administration assigns the first segment of the NDC, 

which identifies the labeler (i.e., the firm that manufactures, repackages, or distributes a 

drug). The labeler assigns the second and third segments. The second segment identifies 

a specific strength, dosage form, and formulation (e.g., 20 mg capsules) and the third 

segment identifies package size and type (e.g., 100 capsules in a bottle). A drug can have 

multiple NDCs associated with it. For example, a drug made by one manufacturer, in one 

strength or dosage form, but in three package sizes would have three NDCs where the 

first and second segments are identical and the third segment differs for each package 

size.
Appendix I: Scope and Methodology

Page 16 GAO-13-358 DOD and VA Direct Purchase Drug Prices

The drug sample was selected to include the top 50 brand-name and top 

50 generic drugs; 25 of the brand-name drugs and 25 of the generic 

drugs were selected on the basis of the combined DOD and VA utilization 

ranks, and the other 25 brand-name and 25 generic drugs were selected 

on the basis of the combined DOD and VA expenditure ranks. After 

accounting for drugs that were in both the high-expenditure group and the 

high-utilization group, the final sample contained 43 brand-name drugs 

and 40 generic drugs and accounted for 37.0 percent of DOD utilization, 

31.7 percent of DOD expenditures, 27.7 percent of VA utilization, and 

34.8 percent of VA expenditures for directly purchased prescription drugs 

in the first calendar quarter of 2012.7 (See table I for a list of the drugs in 

the sample.)

 

7

Percentages exclude physician-administered outpatient drugs.
Appendix I: Scope and Methodology

Page 17 GAO-13-358 DOD and VA Direct Purchase Drug Prices

Table 1: Direct Purchase Drug Sample, First Calendar Quarter of 2012

Drug utilization rankinga Drug expenditure ranking

Drug name, strength, 

and dosage form DOD rank VA rank

Rank after

combining DOD

and VA utilization 

ranksb DOD rank VA rank

Rank after 

combining DOD 

and VA expenditure 

ranksb

43 Brand-Name drugs

Abilify (5 mg tablet) 37 46 25

Actos (30 mg tablet) 11 18 5 

Actos (45 mg tablet) 17 22 9 

Advair Diskus 250 50 

(0.25 mg/actuation-0.05 mg/

actuation, disk) 5 64 19

Androgel (1% gel/jelly) 27 71 28

Asacol (400 mg tablet, 

enteric coated) 43 28 15

Atripla (600 mg-200 mg300 mg tablet) 14 4 3 

Carafate (1 gm/10 ml suspension) 44 19 12

Celebrex (200 mg capsule) 4 73 23

Colcrys (0.6 mg tablet) 33 21 13

Combivent (0.09 mg/1 inh-0.018

mg/actuation, aerosol powder) 52 3 15

Copaxone (20 mg/1ml device) 26 10 6 

Crestor (20 mg tablet) 66 17 19 38 35 21

Cymbalta (30 mg capsule, 

delayed release) 31 43 22

Cymbalta (60 mg capsule, 

delayed release) 13 25 7 

Gleevec (400 mg tablet) 49 7 18

Januvia (100 mg tablet) 7 48 15

Klor Con 10 (10 meq tablet, 

extended release) 20 7 4 

Lantus (100 units/1ml solution) 84 8 25 40 2 10

Levitra (20 mg tablet) 10 60 20

Lidoderm (5% patch, 

extended release) 8 37 12

Lovaza (1 gm capsule, liquid filled) 17 62 16

Namenda (10 mg tablet) 42 27 14 22 16 7 
Appendix I: Scope and Methodology

Page 18 GAO-13-358 DOD and VA Direct Purchase Drug Prices

Drug utilization rankinga Drug expenditure ranking

Drug name, strength, 

and dosage form DOD rank VA rank

Rank after

combining DOD

and VA utilization 

ranksb DOD rank VA rank

Rank after 

combining DOD 

and VA expenditure 

ranksb

Nexium (40 mg capsule, 

delayed release) 3 39 10

Nitrostat (0.4 mg tablet) 82 6 21

Periogard (0.12% liquid) 1 44 9 

Plavix (75 mg tablet) 7 3 3 1 1 1 

Prevident 5000 plus (1.1% cream) 4 60 13

Singulair (10 mg tablet) 6 34 6 2 17 4 

Spiriva (18 mcg capsule) 18 12 5 6 6 2 

Symbicort (160 mcg-4.5 mcg/ 

1 actuation, aerosol liquid) 58 19 23

Synthroid (0.025 mg tablet) 65 26 23

Synthroid (0.05 mg tablet) 24 16 6 

Synthroid (0.075 mg tablet) 16 24 6 

Synthroid (0.088mg tablet) 40 51 23

Synthroid (0.1mg tablet) 28 23 10

Synthroid (0.112 mg tablet) 50 43 26

Synthroid (0.125 mg tablet) 59 29 21

Synthroid (0.15 mg tablet) 57 38 27

Thermazene (1% cream) 68 15 19

Tricor (145 mg tablet) 35 46 18

Truvada (200 mg-300mg tablet) 47 8 15

Zetia (10 mg tablet) 15 65 17 18 36 13

40 Generic Drugs

Amlodipine besylate (5 mg tablet) 19 32 19

Amlodipine besylate (10 mg tablet) 29 11 14

APAP oxycodone 

(325 mg-5 mg tablet) 27 23 17

Atenolol (25 mg tablet) 30 44 27

Atenolol (50 mg tablet) 22 37 24

Azithromycin (250 mg tablet) 14 51 12

Carbidopa levodopa 

(25 mg-100 mg tablet) 32 36 16

Chlorhexidine gluconate 

(0.12% liquid) 17 42 24
Appendix I: Scope and Methodology

Page 19 GAO-13-358 DOD and VA Direct Purchase Drug Prices

Drug utilization rankinga Drug expenditure ranking

Drug name, strength, 

and dosage form DOD rank VA rank

Rank after

combining DOD

and VA utilization 

ranksb DOD rank VA rank

Rank after 

combining DOD 

and VA expenditure 

ranksb

Clonidine (0.3 mg/24 hr 

patch, extended release) 61 28 25

Cyclobenzaprine HCL (10 mg tablet) 28 26 22

Finasteride (5 mg tablet) 45 21 26 16 2 3 

Fluticasone propionate 

(0.05 mg/actuation, spray) 1 46 8 

Gabapentin (300 mg capsule) 11 4 4 7 3 1 

Gabapentin (600 mg tablet) 18 63 22

Gemfibrozil (600 mg tablet) 45 17 10

Glyburide (5 mg tablet) 54 22 28

Lactulose (10 gm/15 ml solution) 25 7 10

Lisinopril (10 mg tablet) 16 35 19

Lisinopril (20 mg tablet) 14 25 13 41 43 24

Lisinopril (40 mg tablet) 21 9 9 51 12 11

Metformin HCL (500 mg tablet) 5 10 4 24 18 7 

Metformin HCL (1000 mg tablet) 13 5 7 26 7 5 

Metoprolol succinate (25 mg tablet, 

extended release) 5 62 15

Metoprolol succinate (50 mg tablet, 

extended release) 2 31 5 

Metoprolol succinate (100 mg tablet, 

extended release) 3 27 4 

Metoprolol succinate (200 mg tablet, 

extended release) 44 21 12

Metoprolol tartrate (25 mg tablet) 34 16 17

Metoprolol tartrate (50 mg tablet) 24 8 10

Minocycline HCL (100 mg capsule) 48 23 20

Naproxen (500 mg tablet) 15 36 19

Olanzapine (10 mg tablet) 77 5 23

Omeprazole (20 mg capsule, 

delayed release) 4 17 8 6 11 2 

Pravastatin sodium (40 mg tablet) 34 38 21

Ranitidine (150 mg tablet) 18 15 12

Sertraline HCL (100 mg tablet) 31 35 14

Simvastatin (20 mg tablet) 7 40 16

Simvastatin (40 mg tablet) 12 31 15 30 39 18
Appendix I: Scope and Methodology

Page 20 GAO-13-358 DOD and VA Direct Purchase Drug Prices

Drug utilization rankinga Drug expenditure ranking

Drug name, strength, 

and dosage form DOD rank VA rank

Rank after

combining DOD

and VA utilization 

ranksb DOD rank VA rank

Rank after 

combining DOD 

and VA expenditure 

ranksb

Tamsulosin HCL (0.4 mg capsule) 37 20 23 37 15 9 

Tramadol HCL (50 mg tablet) 9 3 3 72 20 26

Valacyclovir HCL (500 mg tablet) 9 60 18

Source: GAO analysis of DOD, VA, and Truven Health Analytics data.

Notes: The Truven Health Analytics data used were Red Book data. We excluded physicianadministered outpatient drugs, over-the-counter drugs, and certain items such as bandages, syringes, 

needles, diabetes test strips, saline, and water for irrigation. Drug utilization and expenditures were 

determined by aggregating data for all national drug codes (NDC) corresponding to the same drug 

name, strength, and dosage form. If rankings are provided in either the utilization columns or the 

expenditure columns but not both, the drug was selected for the sample because combining the DOD 

and VA ranks placed the drug among the top drugs for only one of these categories. If rankings are 

provided in both the utilization columns and the expenditure columns, then combining the DOD and 

VA ranks placed the drug among the top drugs for both categories.

a

Utilization was determined on the basis of the total number of units purchased; units were defined on 

the basis of the National Council for Prescription Drug Programs (NCPDP) Billing Unit Standard. 

NCPDP developed the Billing Unit Standard to assist in consistent and accurate billing of 

pharmaceutical products and to standardize the reporting of units to the Centers for Medicare & 

Medicaid Services for rebate purposes. Generally, these standards report items in one of three units: 

each (when a product is measured in discrete units such as tablets, capsules, vials, or kits), milliliters 

(when a product is measured in liquid volume), and grams (when a product is measured by weight). 

The use of these standards may cause certain drugs (e.g., liquids) to have a higher utilization rank 

than they would if a different method had been used.

b

Rankings that do not appear in the combined rankings columns (e.g., rank 1 for combined DOD and 

VA utilization) corresponded to items such as saline that we excluded from the sample.

After selecting the sample, we calculated average unit prices paid by 

DOD and VA for all individual drugs by dividing total expenditures by total 

utilization for each drug. We also calculated average unit prices for the 

entire sample, the subset of brand-name drugs, and the subset of generic 

drugs by dividing the total expenditures for all relevant drugs by the total 

utilization of those drugs. In order to maintain the confidentiality of drug

prices, in each case we converted from absolute prices to relative prices 

by assigning 100.0 to the lowest price and determining the higher price as 

a percentage above the lowest price. We compared the average unit 

prices obtained by DOD and VA for each drug to the Federal Supply 

Schedule (FSS) and Big Four prices available to these agencies.8

 

8

A given drug corresponds to one or more NDCs, each representing a different labeler or 

different package size. Each NDC may have an FSS price and a Big Four price available 

to government purchasers, so there may be many such prices corresponding to a given 

drug. We compared the average unit prices paid by DOD and VA for each drug to all FSS 

and Big Four prices corresponding to the drug.

We 
Appendix I: Scope and Methodology

Page 21 GAO-13-358 DOD and VA Direct Purchase Drug Prices

interviewed DOD and VA officials about drug purchasing approaches they 

use and factors affecting the prices they are able to obtain. Finally, we 

determined the maximum potential savings that might have been 

obtained if each agency had been able to obtain the lower of the DOD 

and VA average unit prices for each of the 83 drugs in the sample. The 

results of our analyses are limited to the 83 high-utilization and highexpenditure drugs in our sample for the first calendar quarter of 2012 and 

are not necessarily applicable across all drugs. 
Appendix II: Relative Prices Paid by DOD and 

VA for the 83 Drugs in the Direct Purchase 

Sample

Page 22 GAO-13-358 DOD and VA Direct Purchase Drug Prices

Figure 3 shows the 55 drugs (out of 83 drugs in our sample) for which the 

Department of Defense (DOD) paid a higher average unit price than the 

Department of Veterans Affairs (VA) and the percentage by which the 

DOD price exceeded the VA price. Figure 4 shows the 28 drugs (out of 

83) for which VA paid a higher average unit price than DOD and the 

percentage by which the VA price exceeded the DOD price.

Appendix II: Relative Prices Paid by DOD and 

VA for the 83 Drugs in the Direct Purchase 

Sample 
Appendix II: Relative Prices Paid by DOD and 

VA for the 83 Drugs in the Direct Purchase 

Sample

Page 23 GAO-13-358 DOD and VA Direct Purchase Drug Prices

Figure 3: Drugs for Which DOD Paid a Higher Average Unit Price Than VA, First Calendar Quarter of 2012

Note: The Truven Health Analytics data used were Red Book data. 
Appendix II: Relative Prices Paid by DOD and 

VA for the 83 Drugs in the Direct Purchase 

Sample

Page 24 GAO-13-358 DOD and VA Direct Purchase Drug Prices

Figure 4: Drugs for Which VA Paid a Higher Average Unit Price Than DOD, First Calendar Quarter of 2012

Note: The Truven Health Analytics data used were Red Book data.
Appendix III: Comments from the Department 

of Defense

Page 25 GAO-13-358 DOD and VA Direct Purchase Drug Prices

Appendix III: Comments from the 

Department of Defense

Note: Page numbers in 

the draft report may differ 

from those in this report. 
Appendix III: Comments from the Department 

of Defense

Page 26 GAO-13-358 DOD and VA Direct Purchase Drug Prices
Appendix IV: Comments from the Department 

of Veterans Affairs

Page 27 GAO-13-358 DOD and VA Direct Purchase Drug Prices

Appendix IV: Comments from the 

Department of Veterans Affairs
Appendix IV: Comments from the Department 

of Veterans Affairs

Page 28 GAO-13-358 DOD and VA Direct Purchase Drug Prices
Appendix V: GAO Contact and Staff 

Acknowledgments

Page 29 GAO-13-358 DOD and VA Direct Purchase Drug Prices

John E. Dicken, (202) 512-7114 or dickenj@gao.gov

In addition to the contact named above, key contributors to this report 

were Robert Copeland, Assistant Director; Zhi Boon; Karen Howard; 

Laurie Pachter; and Carmen Rivera-Lowitt.

Appendix V: GAO Contact and Staff 

Acknowledgments 

GAO Contact 

Staff 

Acknowledgments 
Related GAO Products

Page 30 GAO-13-358 DOD and VA Direct Purchase Drug Prices

DOD and VA Health Care: Medication Needs during Transitions May Not 

Be Managed for All Service Members. GAO-13-26. Washington, D.C.: 

November 2, 2012.

2012 Annual Report: Opportunities to Reduce Duplication, Overlap 

and Fragmentation, Achieve Savings, and Enhance Revenue. 

GAO-12-342SP. Washington, D.C.: February 28, 2012.

Follow-Up on 2011 Report: Status of Actions Taken to Reduce 

Duplication, Overlap, and Fragmentation, Save Tax Dollars, and Enhance 

Revenue. GAO-12-453SP. Washington, D.C.: February 28, 2012.

Opportunities to Reduce Potential Duplication in Government Programs, 

Save Tax Dollars, and Enhance Revenue. GAO-11-318SP. Washington, 

D.C.: March 1, 2011.

VA Drug Formulary: Drug Review Process Is Standardized at the National 

Level, but Actions Are Needed to Ensure Timely Adjudication of 

Nonformulary Drug Requests. GAO-10-776. Washington, D.C.: 

August 31, 2010.

Prescription Drugs: Overview of Approaches to Control Prescription Drug 

Spending in Federal Programs. GAO-09-819T. Washington, D.C.: 

June 24, 2009.

Military Health Care: TRICARE Cost-Sharing Proposals Would Help 

Offset Increasing Health Care Spending, but Projected Savings Are Likely 

Overestimated. GAO-07-647. Washington, D.C.: May 31, 2007.

Prescription Drugs: An Overview of Approaches to Negotiate Drug Prices 

Used by Other Countries and U.S. Private Payers and Federal Programs. 

GAO-07-358T. Washington, D.C.: January 11, 2007.

Related GAO Products

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