Walgreens Boots Alliance, Inc. (Walgreens) recently settled with the U.S. Government for $269 million over two False Claims Act (FCA) claims involving improper billing. The first claim alleged that Walgreens billed federal health care programs, including Medicare and Medicaid, for distributing insulin pens to hundreds of thousands of individuals that did not require them. That settlement resulted in a $209.2 million payment from the company. The second claim alleged that Walgreens overbilled Medicaid by not disclosing a drug discount program that offered lower drug prices. The company agreed to pay $60 million to settle the accusation.
The CIA alleged in the first settlement that Walgreens systematically enabled pharmacists to dispense less than a full box of five insulin pens. The company then submitted false reimbursement claims data that indicated the total number of daily doses did not exceed program limits. Walgreens received millions of dollars for insulin that was unnecessary and wasted “substantial quantities” of the medication. The second settlement alleged that Walgreens failed to disclose lower prices offered through the Prescription Savings Club Program, when seeking related Medicaid reimbursement. The program was intended to give customers discounts when ordering drugs from Walgreens.
Walgreens entered into a Corporate Integrity Agreement (CIA) with the Department of Health and Human Services (HHS) to build upon its existing compliance program, as part of the settlements. The company “admitted no wrongdoing” in reaching the agreement with HHS. Both settlements arose from the whistle-blower provisions of the FCA.
A CIA is available at: