Dear Mr. Waguespack,The Louisiana Department of Health (LDH) acknowledges receipt of correspondence from the Louisiana Legislative Auditor dated January 10, 2023, regarding a reportable audit finding related to Inadequate Controls over Drug Rebate Collections. LDH appreciates the opportunity to prov...
Dear Mr. Waguespack,The Louisiana Department of Health (LDH) acknowledges receipt of correspondence from the Louisiana Legislative Auditor dated January 10, 2023, regarding a reportable audit finding related to Inadequate Controls over Drug Rebate Collections. LDH appreciates the opportunity to provide this response to your office's findings.Finding: Inadequate Controls over Drug Rebate Collections.Recommendation: LDH should ensure that agency personnel are adequately monitoring contract provisions for the drug rebate program and follow-up procedures are performed for all drug rebate invoices that have not been fully collected or disputed in a timely manner.LDH Response: LDH does not concur with this finding and recommendation.LLA issued a finding April 14, 2022 regarding partially paid invoices. LDH responded to the finding on April 22, 2022 regarding 2021 procedures. LLA immediately audited SFY 2022 after the SFY 2021 finding. As a result, there was not enough time to build out the CAP before the end of the SFY22, June 30, 2022.Based on the finding and response in late April, it was determined Magellan Medicaid Administration would email labelers at the 45-day late letter mark. The 45-day mark for the May 2022 invoicing cycle was on July 11, 2022. The 45-day mark before that would have been April 11, 2022, before the finding.In the brief interim before the end of SFY 2022, measures were taken by LDH and Magellan (end of April, May & June) to begin setting up the mechanisms to address collections on partial payment accounts. First quarter partial payment accounts were addressed with the 45-day Dunning Notices, July 11, 2022 and are currently being monitored. Magellan has been manually sending Dunning Notices to all manufacturers that made partial payments. This procedural change is to help increase collection rates.Corrective Action Plan and progress addressing the findings are listed below:1) Magellan regularly provides LDH with an Aged Receivables and Disputes Dashboard. This visual spreadsheet shows open balance data for federal and supplemental rebate programs, along with original invoice information, collection rates, and open disputes over the past 4 quarters (starting the week of April 24, 2022). LDH holds weekly meetings with Magellan to review the data and recommend changes. The dashboard is updated quarterly.2) Magellan has built a team to work on rebate related manufacturer operations focused on accounts receivables and disputes.? Magellan has built a manufacturer-focused team.? Magellan has addressed partial payments by sending Dunning Notices to manufacturers.3) Magellan will begin emailing all labelers with outstanding balances. An email template is being created and will be provided to LDH during the week of April 24, 2022 for approval.? LDH approved an-email template. However, after additional consideration it was determined this was not needed.? Upon further review and discussion by LDH and Magellan it was determined that Magellan would not email all Labelers with outstanding balances over 150 days. The "late" letters Magellan sends to manufacturers at 45-day, 75-day, and 90-day marks were sufficient. The letters serve as a 60-day letter, per ODR statute. The 45-day and the 75- day letters can suffice as the reminder letter to be sent to the debtor to pay the debt within 60 days before transfer to ODR.4) Magellan will change its automated Dunning Notices process to include labelers that made partial payments. This procedural change will continue to help increase the collection rate.? Magellan began emailing all labelers with partial payments. Magellan sent the first email on 7/11/22 to all labelers that made partial payments to the 1Q22 invoices? The automated Dunning Notices process will be changed to include labelers that made partial payments as part of the RxLink implementation, which is planned to go live in February 2023.? In the interim, the updated process for late letters that includes partial payments has been:1. Dunning #IA sent through an automated process to labelers that made no payments- 45 days after original postmark2. Dunning #1B manually emailed to labelers that made partial payments and for which the total outstanding balance is greater than $25 - 45 days after original postmark.3. Dunning #2A sent through an automated process to labelers that made no payments - 75 days after original postmark4. Dunning #2B manually emailed to labelers that made partial payments and for which the total outstanding balance is greater than $25 - 75 days after original postmark5. Next Quarterly Invoice plus Prior Period Statement- includes total balance due for prior periods6. Dunning #3A sent through an automated process to labelers that made no payments - 90 days after original postmark7. Dunning #3B manually emailed to labelers that made partial payments and for which the total outstanding balance is greater than $25 - 90 days after original postmark8. Dunning #4 sent through an automated process to labelers that made no payments - 210 days after original postmarkEffective 02/2023, all dunning letters will be sent through an automated process to labelers that made no payments and to labelers that made partial payments. This will be part of RxLink Implementation.In regards to additional procedures for collection of partial payments, Magellan previously invoiced quarterly and included invoices for past quarters not fully paid in the subsequent quarter. In addition, after 210 days of not receiving payment in full, Magellan's Rebate team reviewed outstanding balances and reached out to manufacturers.You may contact Tara A. LeBlanc at (225) 219-7810 or via e-mail at Tara.LeBlanc@LA.GOV or Germaine Becks-Moody, Medicaid Program Manager at (225) 342-9479 or via email at germaine.becks-moody@la.gov with any questions about this matter.