For years, pharmacy benefit managers (PBMs) and drug manufacturers have paid rebates to the Office of Personnel Management (OPM) under the Federal Employees Health Benefits (FEHB) Program. These rebates are supposed to help reduce the cost of medications for federal employees, retirees, and their families.

Yet millions of FEHB participants remain in the dark about:

How much rebate money OPM actually received from PBMs
✅Which drugs generated the top rebates
✅Whether those rebates were used to lower prescription costs for the enrollees who paid for them
✅Whether any rebate funds were diverted away from patients and premiums into untracked administrative or general plan funds

Case in point — the Express Scripts audit
A March 2024 audit by the Office of Personnel Management’s (OPM) Office of Inspector General found that PBM giant Express Scripts overcharged the FEHB Program by nearly $44.9 million between 2016 and 2021. The audit revealed that Express Scripts and its affiliate withheld millions of dollars in drug-manufacturer rebates instead of passing them back in full, as required by contract, including approximately $15.8 million in withheld rebates by its sister company, Ascent Health Services. 

Other reports described nearly half of the total overcharges as stemming from rebates negotiated but not fully returned to the plan. 

Yet this is just one audit, one PBM, and one health plan out of dozens of FEHB carriers and contracts.

We Demand Immediate Action
We call on OPM to conduct — and publicly release — a full, independent audit of all PBM rebates collected under the FEHB Program from 2020 to the present, including:

✅ 1. Total Rebates Collected
Provide a year-by-year, carrier-by-carrier breakdown of all PBM rebates OPM and FEHB plans received.

✅ 2. Rebate Sources & Drug Detail

Identify:

The top drugs and drug classes generating rebate income
Total rebate dollars per drug category
Whether rebate amounts for specific drugs were used to lower costs for those drugs
✅ 3. Rebate Usage Transparency
Reveal:

How rebate funds were spent or allocated
Whether any rebates were used to reduce premiums or out-of-pocket drug costs
Which rebates, if any, were diverted for non-drug purposes
✅ 4. Long-Term Rebate Disclosure
Require OPM to implement a public annual rebate disclosure, detailing:

Total rebates collected from PBMs
How rebates were applied to premiums, drug costs, or administrative expenses
Prescriptions and drug types tied to the biggest rebates

Why This Matters
Federal employees and retirees are paying rising premiums and drug prices, while payments intended to reduce costs are being negotiated and withheld behind closed doors. Without transparency, FEHB enrollees can’t determine if:

Their higher costs are justified
Rebate dollars were used to benefit them
Funds were mismanaged or withheld by PBMs like Express Scripts
This affects:

Federal employees and retirees choked by higher prescription costs
Family budgets and fixed incomes relying on FEHB
Taxpayers funding the federal workforce benefit system
Our Request Is Simple
OPM must commit to full transparency and accountability by:
✅Auditing ALL PBM rebate activity across the FEHB Program (not just one contract)
✅ Publicly reporting which drugs generated rebates
✅Explaining how these rebates were used — or why they weren’t used to reduce drug costs for plan members

Anything less is a failure of oversight and a breach of trust.