Investor Presentaiton
OHA performs minimal monitoring of CCOS and PBMs
OHA's process for monitoring CCO contracts is coordinated by the agency's quality assurance team.
Most contract deliverables are received by the quality assurance team and then sent to subject matter
experts within OHA for review. For PBM-specific deliverables, the subject matter experts are OPDP
staff. 31 This creates a potential conflict of interest as OPDP is a competing PBM.
Even with efforts to exercise professional independence, there still exists an appearance of competing
interests. Additionally, content monitoring of certain reports is not being done at all because of this
conflict of interest. OHA management indicated this situation is due to an ongoing lack of staff within
the quality assurance team that have experience with PBMs. They are considering adding personnel
with pharmacy experience to the team, which could move PBM contract provision review out of OPDP.
OHA should assign staff without a conflict of interest to monitor CCO and PBM compliance.
OHA has developed some controls specific to PBMs, which include contract reviews, market checks,
and pay-for-performance checks. These are improvements over past controls, but do not address
high-risk areas or provide reasonable assurance PBMs are compliant with contract provisions.
OHA reviewed contracts between CCOS and their PBMs after the new provisions were put in place. This
was done to ensure OHA's PBM-specific requirements were incorporated. However, contract reviews
31 OPDP transitioned to ArrayRx on January 1, 2022. See OHA's website for more information.
Oregon Secretary of State | Report 2023-25 | August 2023 | page 30View entire presentation