Rebate Audit Elements
- Rebate guarantee verification: Verify that rebates received meet or exceed contracted guarantees
- Rebate calculation review: Review the methodology used to calculate rebates
- Manufacturer contract access: Request access to manufacturer rebate contracts (often resisted by PBMs)
- Rebate timing: Verify that rebates are paid within the contracted timeframe
- Rebate reconciliation: Reconcile rebates received against claims data to verify accuracy
True Net Cost Calculation
True net cost = gross drug cost - rebates - other credits (DIR fees, administrative fee credits). Calculating true net cost requires access to all rebate and credit data — which PBMs often resist providing. A transparent PBM contract provides full access to rebate data and a clear true net cost calculation.
Manufacturer Contract Access
IQ Insight
Requesting access to manufacturer rebate contracts is the most effective way to verify rebate pass-through — and the most resisted by PBMs. PBMs typically claim manufacturer contracts are confidential. However, employers have a right to verify that rebates are being passed through as contracted. An independent audit firm with experience in PBM audits can often obtain this information through indirect means.