Federally excluded VA-resident NPIs prescribing Medicare Part D (CY 2023)
Part D adds the prescribing dimension: an excluded prescriber writing reimbursed prescriptions. H30b joins the same 125-NPI VA cohort against the CMS Medicare Part D Prescribers by Provider file. Opioid prescribing by federally-excluded NPIs is a particularly elevated signal — the 21st Century Cures Act and 2018 SUPPORT Act extended controlled-substance enforcement to specifically cover Medicare/Medicaid prescribers.
Headline
416 of 6,840 currently-active federally-excluded NPIs (across 52 state cohorts) prescribed Medicare Part D in CY 2023 (full-window drug cost $119,792,842; 138 of 416 were opioid prescribers with 65,309 opioid claims). Of those, **6 were prescribing STRICTLY POST-EXCLUSION** (LEIE or SAM exclusion-effective year before 2023), with $8,662,186 drug cost and 2 opioid prescribers writing 137 opioid claims. The strict-post-exclusion subset is the regulatorily significant signal — pre-exclusion prescribing was authorized at the time.
6 / 6.8K = 0.09%
unit: count
Null hypothesis
Zero currently-LEIE/SAM-excluded VA-resident NPIs appear as prescribers in the CMS Medicare Part D Prescribers by Provider file for CY 2023.
Denominator
VA federally-excluded cohort (125 NPIs, active LEIE or SAM, score >= 1.5; VA-resident per NPPES practice state) joined against every NPI in the Medicare Part D by-Provider file.
Data source
CMS Medicare Part D Prescribers — by Provider (MUP_DPR_RY25_P04_V10_DY23_NPI.csv, ~130 MB, NPI-aggregated CY 2023). See `analysis/claims_sources/medicare_partd.py`.
Notes
Per-state CSV at /api/v1/states/<state>/h30b-excluded-prescribing-partd.csv carries drug cost + claims + beneficiaries + opioid metrics + exclusion source. Opioid prescribing by federally-excluded NPIs is a particularly elevated signal because the 21st Century Cures Act and 2018 SUPPORT Act extended controlled-substance enforcement to specifically cover Medicaid/Medicare prescribers; this should feed directly into state PI + DEA referral queues.