Forensic auditing. We have the receipts. BILLIONS+ in Unapproved Drug fraud the PBMs and the system don't want you to see. Whistleblower intelligence. ๐บ๐ธ
Texas paid PBMs to screen every Medicaid pharmacy claim.
502,442 claims for FDA-unapproved drugs got through anyway. $52 million, 2023 to 2025.
Not a rounding error. A gate that never closed.
Forensic Recovery Series, No. 1 of 51: TEXAS
The #1 best-selling prenatal vitamin in America costs $18.99 for a 90-day supply on Amazon. 21 cents a day.
Missouri Medicaid paid $484,206 for a prenatal product that was never FDA-approved, run entirely through the state's own fee-for-service channel.
105,166 unapproved claims total. $2.8 million, 2023 to 2025.
Forensic Recovery Series, No. 19 of 51: MISSOURI
The receipts, from CMS State Drug Utilization Data:
105,166 unapproved-drug claims through state-run fee-for-service. $2,779,336 reimbursed.
Largest line item: a generic prenatal vitamin, NDC 39328010610. $484,206, never FDA-approved.
The comparator, receipt attached: #1 best seller in the category, USP verified, $18.99 for 90 days.
Statutory ceiling: $3.02B (31 U.S.C. ยง 3729, 28 C.F.R. ยง 85.5).
120,453 claims. The most of any state so far. Every one screened. Every one paid.
Washington must demand this back.
Next: Missouri.
Follow for all 50 states plus DC.
Washington Medicaid processed 120,453 unapproved-drug claims through its PBM channel, the highest claim count in the series so far.
$2.9 million, 2023 to 2025. Every claim screened by a PBM paid to catch it.
Forensic Recovery Series, No. 18 of 51: WASHINGTON
The receipts, from CMS State Drug Utilization Data:
120,453 unapproved-drug claims through the managed-care/PBM channel. $2,866,021 reimbursed.
Largest line item: a prenatal vitamin, NDC 39328010610, Patrin Pharma. The FDA's own listing, verbatim: "This drug has not been found by FDA to be safe and effective, and this labeling has not been approved by FDA."
$245,414 across 27,591 scripts. Paid anyway.
With 120,453 separate claims at $14,308 to $28,619 per claim, Washington's statutory ceiling is $3.46B (31 U.S.C. ยง 3729, 28 C.F.R. ยง 85.5).
Colorado Medicaid paid $453,369 for a single unapproved prenatal product, Complete Natal, run entirely through the state's own fee-for-service channel.
75,315 unapproved claims total. $3.4 million, 2023 to 2025.
Forensic Recovery Series, No. 17 of 51: COLORADO
The receipts, from CMS State Drug Utilization Data:
75,315 unapproved-drug claims through state-run fee-for-service. $3,439,398 reimbursed.
Largest line item: Complete Natal, NDC 13811001030. $453,369, never FDA-approved.
A comparable prenatal with the same key nutrients, the #1 best seller in the category: $18.99 for a 90-day supply on Amazon. 21 cents a day.
Statutory ceiling: $2.17B (31 U.S.C. ยง 3729, 28 C.F.R. ยง 85.5).
Wisconsin Medicaid paid $1 million for a single unapproved prenatal vitamin, Se-Natal 1, with no PBM in between.
96,503 unapproved claims total. $3.7 million, 2023 to 2025.
Forensic Recovery Series, No. 16 of 51: WISCONSIN
The receipts, from CMS State Drug Utilization Data:
96,503 unapproved-drug claims through state-run fee-for-service. $3,662,854 reimbursed.
Largest line item: Se-Natal 1, NDC 13925011601. $1,002,359, never FDA-approved.
A comparable prenatal with the same key nutrients, the #1 best seller in the category: $18.99 for a 90-day supply on Amazon. 21 cents a day.
Statutory ceiling: $2.77B (31 U.S.C. ยง 3729, 28 C.F.R. ยง 85.5).
The state knows their names. So do the companies. $3.8 million still got through.
Arizona must demand this back.
Next: Wisconsin.
Follow for all 50 states plus DC.
Arizona pays managed care plans to run its Medicaid drug benefit. Every plan hires a PBM to screen every claim.
98,511 unapproved claims got through anyway. $3.8 million, 2023 to 2025.
Forensic Recovery Series, No. 15 of 51: ARIZONA
The receipts, from CMS State Drug Utilization Data:
98,511 unapproved-drug claims through the managed-care/PBM channel. $3,756,592 reimbursed.
Three PBMs on duty: CVS Caremark (Mercy Care, Molina Healthcare), Express Scripts (Banner University Family Care, Centene plans from 2024), Optum Rx (UnitedHealthcare Community Plan). Per AHCCCS pharmacy claims processing grids.
Largest line item: Armour Thyroid, NDC 00456046001, an unapproved thyroid hormone product. $419,329 across 4,739 scripts, $88.49 per script.
Statutory ceiling: $2.83B (31 U.S.C. ยง 3729, 28 C.F.R. ยง 85.5).
Same product. Different state. Same gatekeepers paid to catch it, didn't.
Illinois must demand this back.
Next: Arizona. Three named PBMs, one state.
Follow for all 50 states plus DC.
Illinois is the second state this series has caught paying for the exact same unapproved lidocaine cream Michigan paid for.
26,144 prescriptions. $1.4 million on this one product. $4.6 million on unapproved drugs overall, 2023 to 2025.
Forensic Recovery Series, No. 14 of 51: ILLINOIS
The receipts, from CMS State Drug Utilization Data:
129,998 unapproved-drug claims through the managed-care/PBM channel. $4,644,552 reimbursed.
Largest line item: lidocaine hydrochloride 3% cream, NDC 69367020285, the same product that led Michigan. $1,380,017 across 26,144 prescriptions, dispensed as one 85-gram tube per script, $52.79 each.
The identical 85-gram size, in a stronger 4% OTC formula: $4.36 on Amazon.
Statutory ceiling: $3.73B (31 U.S.C. ยง 3729, 28 C.F.R. ยง 85.5).
Nearly 280,000 claims. Every one screened by a gatekeeper paid to catch it. Every one paid.
Michigan must demand this back.
Next: Oklahoma.
Follow for all 50 states plus DC.
Michigan Medicaid paid 34,810 prescriptions for a lidocaine cream the FDA never approved.
$1.3 million on this single product. $5.0 million on unapproved drugs overall, 2023 to 2025.
Forensic Recovery Series, No. 12 of 51: MICHIGAN
The receipts, from CMS State Drug Utilization Data:
278,069 unapproved-drug claims through the managed-care/PBM channel. $4,981,339 reimbursed.
Largest line item: lidocaine hydrochloride 3% cream, NDC 69367020285. $1,312,279 across 34,810 prescriptions, dispensed as one 85-gram tube per script, $37.70 each.
The identical 85-gram size, in a stronger 4% OTC formula: $4.36 on Amazon.
With 278,069 separate claims, each a separate violation, Michigan's statutory ceiling is $7.97B (31 U.S.C. ยง 3729, 28 C.F.R. ยง 85.5).