Within the last two weeks, AstraZeneca sent numerous letters to pharmacies requesting information regarding dispensing and purchasing FARXIGA® in 2024. These letters inform pharmacies that AstraZeneca has identified data discrepancies in billing and purchasing FARXIGA® for each flagged pharmacy.
AstraZeneca alleges that it had perform reconciliation of purchase and dispensing data for each identified pharmacy. The reconciliation has identified material inconsistencies for the calendar year 2024. Specifically, AstraZeneca audits discovered that these pharmacies have not purchased a quantity of FARXIGA® tablets sufficient to support reported dispensing. Dispensing data allegedly was derived from rebate claims submitted by PBMs and plans to the manufacturer and the purchase data was reported by the wholesalers.
Our attempts to reach the manufacturer to better understand the nature of these audits and negotiate a confidentiality agreement before our clients disclose such data were unsuccessful.
I strongly caution pharmacies from volunteering this highly sensitive information as it may backfire due to the reporting requirements that AstraZeneca has with state and federal agencies.
I would like to remind pharmacies that they do not have contractual or legal obligations to disclose their dispensing and purchase data to AstraZeneca. If your pharmacy did receive this request from AstraZeneca, please contact our firm to better understand what could be done to mitigate risks involved.
While pharmacies lose money on dispensing FARXIGA® and may dispense a generic version (making a very small profit but keeping the patient), billing for FARXIGA® under this scenario does not obliviate risks of potential fraudulent claims or non-compliance. Reimbursement issues should be addressed directly with the plans and CMS.
With low reimbursement rates, similar manufacturers’ audits might become more routine and compliance is paramount in order to avoid being flagged for further investigation. Pharmacies should review their billing practices to identify any overpayments or billing discrepancies. Medicare, for example, has strict rules on how and when the overpayment must be returned to the plan.
Please contact your legal counsel or our firm if you have received these requests or any audit/inspection requests pertaining to FARXIGA® from state or federal government agencies.