On May 10, 2012, the HHS Office of Inspector General (OIG) issued a report entitled “Retail Pharmacies with Questionable Part D Billing.”  The OIG identified more than 2,600 retail pharmacies in 2009 that had what the OIG characterizes as “questionable billing” for Part D drugs (e.g., extremely high dollar amounts or numbers of prescriptions per beneficiary or per prescriber, or high percentage of prescriptions for Schedule II or III drugs, brand-name drugs, or refills). While the OIG acknowledges that “some of this billing may be legitimate,” the OIG believes that these pharmacies warrant further scrutiny. The OIG also observes that the Miami, Los Angeles, and Detroit areas were the most likely to have pharmacies with questionable billing. The OIG makes a number of recommendations to CMS, including strengthening the Medicare Drug Integrity Contractor’s monitoring of pharmacies, requiring Part D plan sponsors to refer potential fraud and abuse incidents that may warrant further investigation, developing risk scores for pharmacies, strengthening CMS compliance plan audits, and following up on pharmacies identified by the OIG as having questionable billing.