Vickers Consulting

Pharmacy benefit compliance to identify illegal FDA-unapproved medications wrongly billed by PBMs, reducing risk to patients, pharmacies, and plans.

[Veritas_Intel @verumfAI]

Just over half of Rhode Island's entire unapproved-drug bill is one bottle of vitamins.

Folite. $1,501.09 per prescription. 99 prescriptions, $148,608, and its own label reads DIETARY SUPPLEMENT.

Its five ingredients cost $57.00 on Amazon, delivered. The receipt is in our pinned Special Report, where this product's national total is $112.9 million.

6,169 unapproved claims. $294,828. 2023 to 2025.

@AGNeronha must demand this back.

Forensic Recovery Series, No. 48 of 52: RHODE ISLAND

[Veritas_Intel @verumfAI]

South Dakota bought the food too.

Enlyte, the medical food from Delaware's episode, at an even higher price: $163.97 a bottle, 534 times. $87,558. Two states, $200,656, for a product whose own DailyMed category is MEDICAL FOOD.

5,250 unapproved claims. $297,327. All of it through the state's own fee-for-service program.

@SDAttorneyGen must demand this back.

Forensic Recovery Series, No. 47 of 52: SOUTH DAKOTA

[Veritas_Intel @verumfAI]

Enlyte's own label, on the National Library of Medicine's DailyMed: Category, MEDICAL FOOD.

Not an approved drug. Not a dietary supplement. Food.

Delaware Medicaid paid $154.72 a bottle for it, 731 times. $113,098.

13,299 unapproved claims. $366,381. 2023 to 2025.

@DE_DOJ must demand this back.

Forensic Recovery Series, No. 46 of 52: DELAWARE

[Veritas_Intel @verumfAI]

Vermont bought nothing this series hasn't already documented. That is the point.

Its three largest unapproved line items: Armour Thyroid, now in its thirteenth state. The children's fluoride drops whose own label reads DIETARY SUPPLEMENT, third state. The same generic prenatal vitamin, twelfth.

All of it through Vermont's own fee-for-service program. No PBM anywhere in this state's data.

13,063 unapproved claims. $399,232. 2023 to 2025.

Vermont must demand this back.

Forensic Recovery Series, No. 45 of 52: VERMONT

[Veritas_Intel @verumfAI]

$2,130,962.

This series' running total for dried, ground animal thyroid gland just crossed two million dollars, in its ninth state.

In Alaska it is the entire top three: NP Thyroid and Armour Thyroid. 3,079 prescriptions, $133,637, every claim through the state's own fee-for-service program.

The FDA's compliance guidance on these products is due by the end of this month.

10,312 unapproved claims. $421,296. 2023 to 2025.

Alaska must demand this back.

Forensic Recovery Series, No. 41 of 51: ALASKA

[Veritas_Intel @verumfAI]

$1,997,325.

That is this series' running total for dried, ground animal thyroid gland, never FDA approved, across eight states, after Maine adds $110,728.

In Maine, no single product outspent a generic prenatal vitamin. But the largest category was thyroid extract, holding ranks two and three, all through the state's own fee-for-service program.

19,488 unapproved claims. $460,478. 2023 to 2025.

Maine must demand this back.

Forensic Recovery Series, No. 39 of 51: MAINE

[Veritas_Intel @verumfAI]

Two of Mississippi Medicaid's three largest unapproved line items are the same drug from the same company: hyoscyamine, in two forms.

7,901 prescriptions. $149,906. From its own label: "This drug has not been found by FDA to be safe and effective."

The labeler, Acella, appears on FDA's own list of actions to remove unapproved drugs from the market: a 2020 warning letter and two recalls of its unapproved thyroid product.

21,588 unapproved claims. $661,007. 2023 to 2025.

@LynnFitchAG must demand this back.

Forensic Recovery Series, No. 38 of 51: MISSISSIPPI

[Veritas_Intel @verumfAI]

Nearly half of Hawaii's unapproved-drug spending went to one category: ingestible fluoride products for children.

29,541 prescriptions. $300,964. A fluoride multivitamin, and the same fluoride drops whose own label reads DIETARY SUPPLEMENT.

In May 2025, the FDA announced it was moving to take this category off the market, stating these products were never FDA approved.

55,870 unapproved claims. $622,497. 2023 to 2025.

@AtghIgov must demand this back.

Forensic Recovery Series, No. 37 of 51: HAWAII

[Veritas_Intel @verumfAI]

The compounded omeprazole kit is back.

Tennessee's federal data listed it as UNKNOWN. We traced it then: a raw-powder kit, omeprazole and sodium bicarbonate, never submitted to the FDA as a finished product. Georgia paid $14.23 per day of therapy for it.

The same two active ingredients, FDA approved, cost 37 cents a day on Amazon.

34,185 unapproved claims. $1.2 million, split almost evenly between Georgia's PBM channel and the state's own fee-for-service program. Both doors open.

@Georgia_AG must demand this back.

Forensic Recovery Series, No. 36 of 51: GEORGIA

[Veritas_Intel @verumfAI]

Utah is the sixth state in this series where dried, ground animal thyroid gland dominates the unapproved-drug data. Here it is the entire top three.

Armour Thyroid and NP Thyroid. 6,634 prescriptions. $268,877. Not FDA approved, by the FDA's own account.

Running total across six states: at least $1.8 million.

The FDA said it would issue compliance guidance on these products by August 2026. That deadline is this month.

26,936 unapproved claims. $888,772. 2023 to 2025.

@UtahAG must demand this back.

Forensic Recovery Series, No. 34 of 51: UTAH

[Veritas_Intel @verumfAI]

$35.40 per patch.

That is what Nevada Medicaid paid for LenzaPro Flex Patch, lidocaine 4% and menthol 4%. A topical pain patch. Never FDA approved.

$1,429.11 per prescription. The world's No. 1 pain patch brand sells on Amazon for 55 cents apiece.

20,691 unapproved claims. $1.2 million. 2023 to 2025.

@NevadaAG must demand this back.

Forensic Recovery Series, No. 32 of 51: NEVADA

[Veritas_Intel @verumfAI]

We have documented $434,682,390 in Medicaid payments for FDA-unapproved drugs. Fifty states and DC. Three years.

A quarter of it is one product.

Folite. $112,898,236. Folic acid, magnesium, calcium, vitamin D3.

Its own label calls it a dietary supplement.

$49.86 per tablet. One tablet a day. 96% of it paid by California's own fee-for-service program.

@AGRobBonta must demand this back.

Forensic Recovery Series, Special Report: ONE PRODUCT

[Veritas_Intel @verumfAI]

Montana is the fifth state in this series where dried, ground animal thyroid gland is one of the largest unapproved-drug payments Medicaid made.

Kentucky. Oregon. Indiana. Idaho. Montana. At least $1.5 million, and that counts only the top line items.

The FDA said it would issue compliance guidance on these products by August 2026. It is August 2026.

25,748 unapproved claims. $907,370. 2023 to 2025.

@MTAGKnudsen must demand this back.

Forensic Recovery Series, No. 31 of 51: MONTANA

[Veritas_Intel @verumfAI]

The FDA said it would issue compliance guidance on unapproved animal thyroid drugs by August 2026.

It is August 2026.

Idaho Medicaid has paid $369,960 for one of them. 6,488 prescriptions of Armour Thyroid, three strengths, all through the state's own program. No PBM involved.

29,356 unapproved claims. $1.1 million. 2023 to 2025.

@Raul_Labrador must demand this back.

Forensic Recovery Series, No. 30 of 51: IDAHO

[Veritas_Intel @verumfAI]

Maryland Medicaid paid $211.39 for one 10 mL bottle of wart remover. Not FDA approved.

Compound W, the #1 dermatologist recommended brand, is $7.68 for a 9 mL bottle. Same size. Same brush. Sold on a shelf.

For what Maryland paid for one prescription, you could buy 27 bottles at the drugstore.

49,973 unapproved claims. $1.2 million. 2023 to 2025.

@OAGMaryland must demand this back.

Forensic Recovery Series, No. 29 of 51: MARYLAND

[Veritas_Intel @verumfAI]

"This drug has not been found by FDA to be safe and effective."

That sentence is printed on the label of an acne face wash. Minnesota Medicaid paid $79.31 a bottle for it, 2,415 times.

It was not alone. A prescription toothpaste, $64.40. A prenatal vitamin, $386,294.

58,784 unapproved claims. $2.0 million. 2023 to 2025.

@AGEllison must demand this back.

Forensic Recovery Series, No. 28 of 51: MINNESOTA

[Veritas_Intel @verumfAI]

Indiana Medicaid's three largest unapproved-drug payments are the same product, in three different strengths.

Armour Thyroid. 5,168 prescriptions. $367,480. Not FDA approved, by the FDA's own account.

45,788 unapproved claims. $1.7 million. 2023 to 2025.

@AGToddRokita must demand this back.

Forensic Recovery Series, No. 27 of 51: INDIANA

[Veritas_Intel @verumfAI]

"These statements have not been evaluated by the Food and Drug Administration."

That is the disclaimer on the label of a product Massachusetts Medicaid paid for as a prescription drug 11,510 times.

Its FDA listing category is not "drug." It is "dietary supplement."

69,567 unapproved claims. $2.5 million. 2023 to 2025.

Forensic Recovery Series, No. 26 of 51: MASSACHUSETTS

[Veritas_Intel @verumfAI]

Oregon Medicaid's three largest unapproved-drug payments are all the same thing: dried, ground-up animal thyroid gland.

12,019 prescriptions. $446,470. None of it FDA approved.

The FDA's own website says so, and says it will issue compliance guidance on these products by August 2026.

80,961 unapproved claims. $1.8 million. 2023 to 2025.

@AGDanRayfield must demand this back.

Forensic Recovery Series, No. 25 of 51: OREGON

[Veritas_Intel @verumfAI]

New Mexico Medicaid paid two different prices for the same drug, from the same manufacturer, in the same years.

Through its PBMs: $67.50 per mL.
Through its own fee-for-service program: $153.44 per mL.

The drug is phenobarbital. It has been sold in America since before the FDA's approval system existed, and has never been through it.

$1,380,074. That is 53% of every unapproved dollar New Mexico spent.

@NewMexicoDOJ must demand this back.

Forensic Recovery Series, No. 24 of 51: NEW MEXICO