Audit of the Federal Bureau of Prisons Pharmacy Services

Audit Report 06-03
November 2005
Office of the Inspector General

Objectives, Scope, and Methodology

The DOJ OIG conducted this audit to evaluate the BOP Pharmacy Services. The objectives of our audit were to:

  • evaluate the BOP's efforts to reduce its increasing costs of prescription medications;

  • assess whether the BOP ensures adequate controls and safeguards over prescription medications; and

  • assess whether the BOP pharmacies are in compliance with applicable laws, regulations, policies, and procedures.

We conducted our audit in accordance with the Government Auditing Standards. We included such tests as were considered necessary to accomplish the audit objectives. The audit generally covered, but was not limited to, the period of October 2003 through July 2005. We conducted audit work at the sites shown in Figure 25.47

Institution Location
Alderson FPC West Virginia
Atlanta USP Georgia
Atwater USP California
Danbury FCI Connecticut
Florence ADX Colorado
Florence FCI Colorado
Florence USP Colorado
Forrest City FCI (Low) Arkansas
La Tuna FCI New Mexico
Oklahoma City FTC Oklahoma
Oxford FCI Wisconsin
Springfield Medical Center Missouri

To evaluate the BOP's efforts to reduce its increasing costs of prescription medications, we analyzed the BOP's Central Fill proposal. Our analysis included a comprehensive review of the cost-benefit analysis conducted by the BOP in support of the Central Fill proposal. We analyzed purchasing data for the six institutions included in the BOP's analysis during the period of March 2003 to February 2004, and compared it to pricing information provided by the VA, in order to determine estimated gross purchase savings. In addition, we analyzed the BOP's estimate of savings from the elimination of waste by conducting a survey of all BOP pharmacists to determine the percentage of waste that would be reduced by Central Fill. We also analyzed the number of prescriptions and percentage of prescription medication costs that would use Central Fill and determined their impact on the cost-benefit analysis.

To determine estimated prescription medication costs related to waste and other issues, we surveyed all 126 BOP pharmacists. We received responses to 106 (84 percent) surveys. The survey consisted of 40 questions and covered the following topics: (1) training and assessment; (2) access and security; (3) purchasing and receiving; (4) OTC medication; (5) waste and returns; (6) Central Fill; (7) Central Processing; and (8) other areas.

To determine whether the BOP's OTC program statement had been fully implemented, we reviewed OTC medications prescribed at the institutions to ensure that inmates were being referred to the commissary. When appropriate, we also conducted interviews of staff and included questions in our survey to determine the progress towards implementation of the policy throughout the BOP.

To determine whether the BOP ensures adequate controls and safeguards over controlled substances, we reviewed all controlled substances at 11 of the 12 sites included in our audit and identified deficiencies related to the records used to account for controlled substances. Specifically, we performed an accountability audit of controlled substances, which compared the physical inventory that we conducted on site, to an inventory conducted at least 1-year prior to our audit. At the Springfield Medical Center, we judgmentally sampled a selection of 9 of the 12 controlled substances maintained, and conducted an accountability audit that included at least 7 months of data. The accountability audit consisted of:

  • conducting a physical inventory;

  • adding prescriptions, disposals, and transfers out;

  • subtracting out the beginning inventory balance; and

  • subtracting out purchases and transfers in.

All controlled substances were accounted for if the result of the calculation was equal to zero. If the total was not equal to zero, we reviewed additional documentation to attempt to account for all controlled substances. During the accountability audit we reviewed the following records:

  • mainstock perpetual inventory, which includes purchases, transfers in from the substock, transfers out to the substock, and disposal of controlled substances;

  • substock Proof of Use sheets, also known as certificates of disposition, which are used to record the transfers in from the mainstock, the administration of controlled substances to inmates, and transfers back to the mainstock;

  • inmates' MARs, which are used to record the administration of a controlled substance to an inmate;

  • DEA 222 form for the disposal and purchase of controlled substances;

  • controlled substance invoices from the prime vendor; and

  • disposal records provided to the institution by the returns company.

To determine whether the BOP had adequate controls over prescription medication purchases, we reviewed five purchases from the prime vendor and ensured that documentation was maintained and signed off by a supervisor. In addition, we reviewed up to 10 purchases from sources other than the prime vendor to ensure proper documentation. During interviews with pharmacists and the HSA, we asked for detailed descriptions of how the ordering, approving, receiving, and paying processes worked.

To determine whether the BOP pharmacies were in compliance with applicable laws, regulations, policies, and procedures, we selected a sample of approximately 100 prescriptions written from October 2003 through July 2005 at each institution we audited, with the exception of the Oklahoma FTC. Our prescription sample generally consisted of 50 controlled and 50 noncontrolled substances. If an institution did not have 50 prescriptions for controlled substances during the period, we increased our sample of noncontrolled substances for a total sample of about 100 prescriptions. Additionally, if the prescription selected from our random sample was for an inmate that had been transferred or released, we verified the inmate's location by using the BOP's SENTRY system and replaced the sample with a new prescription, because medical files are transferred with the inmates.

For each prescription included in our sample, we reviewed the inmate's medical file to ensure that the appropriate information, such as prescription name, dosage, and instructions were recorded, and that the pharmacist's review was documented. In addition, we reviewed prescriptions for controlled substances to determine if separate prescription forms were completed – including the required information – and to determine if the prescription was written for the allowable time period. For each of the prescriptions included in our sample, we determined whether or not the medication was included in the BOP formulary. For any non-formulary medications, we determined whether the required non-formulary waiver had been obtained.

At each institution included in our audit, we also obtained invoices for prescription medications purchased from October 2003 through July 2005 and selected a sample of at least 100 individual medications. We reviewed each prescription medication in our purchase sample to identify any non formulary medications that were purchased and determined whether the required waiver had been obtained.

In addition, at each site, except Oklahoma FTC, we judgmentally selected at least 20 administrations of controlled substances and ensured that the information on the Proof of Use sheets and MARs agreed. At Oklahoma FTC we only reviewed 10 administrations due to the constant transferring of inmates and their records. We selected our sample based on the Proof of Use sheet and then obtained the inmate's MAR from their medical file and ensured that the MAR agreed with all the information, including drug name, strength, date, time, and quantity.


  1. We also visited the Englewood FCI, Colorado, to obtain background information; however, Englewood FCI is not included in our results.

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