Investor Presentaiton

Pass-through contracts Pass through all costs so payments made to a pharmacy by the PBM agree to the amounts the CCO paid to the PBM; Pay-for-performance contracts PBM shares a portion of discounted drug costs and dispensing fees with CCOS, based on over-performance of agreed upon performance measures. Contracts permit CCOS to perform an annual audit of their PBMs. This optional provision does not specify areas to be audited, which leaves it open to interpretation. Mandating CCOs to obtain a yearly independent audit of high-risk areas could help give OHA reasonable assurance contract terms are being met. It should be noted performing an annual audit does not replace a CCO's responsibility for ongoing monitoring of its PBMs. OHA has the authority to employ a variety of sanctions on CCOs, but often opts for a more collaborative approach. OHA reported examples of providing technical assistance, instead of corrective action, to CCOs for instances of noncompliance. While cooperative, this method may not ensure timely accountability. Without well-defined and communicated escalations steps, it may be difficult for OHA to proactively enforce contract compliance. OHA should add specific contract language or reference procedures that will go into effect if CCOS and PBMs are found to be out of compliance. A move to a single PBM or FFS model would make monitoring easier for OHA. The Barbara Roberts Human Services building, headquarters of the Oregon Health Authority | Source: Gary Halvorson, Oregon State Archives Oregon Secretary of State | Report 2023-25 | August 2023 | page 29

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