Are Your Delivery/Signature Logs PBM Compliant for 2023?
A common component of a pharmacy audit request is the delivery/signature log. Delivery/signature logs are used to prove the patient received their medication and that they received it within the PBM return to stock timeframe. PAAS Audit Assistance members can refer to the PBM Return to Stock Chart on the PAAS National® Member Portal for a list of the major PBMs and their return to stock time frame allowances.
PAAS often sees delivery/signature logs flagged for having a pre-printed delivery date. Several PBMs do not accept these logs because they may not represent the actual delivery date. Here is an example:
Recent Elixir results state, per the Elixir pharmacy manual, “Receipt submitted states “Delivery.” Unless the prescription delivery is through a common courier, an electronic or manual signature should be recorded at time of delivery by the member or designated member representative. For deliveries, the date delivered cannot be pre-printed by the pharmacy.”
Some software systems allow a pharmacy to “scan out” a prescription and flag it for delivery. The driver can take this date/time stamped point of sale receipt (that notates delivery) to the patient’s address and have them sign. PAAS also sees many LTC facility delivery manifests containing a pre-printed date on the document. An auditor is not going to accept/assume the delivery took place the same day as the pre-printed date and will likely flag these logs as invalid. The pharmacy needs to provide documentation of when the delivery took place by having the patient, or representative, date their signature upon delivery. Consider adding a blank line for a handwritten date next to the signature line that can be completed upon delivery.
- PBM Return to Stock requirements apply to retail and LTC pharmacies
- Read the May 2022 Newsline article, Return to Stock – Make It a Priority
- A complete delivery/signature log should contain:
- Patient name
- Prescription number
- Date filled or fill number
- Date delivered – cannot be pre-printed
- Delivery address – pharmacy, patient, or facility
- Signature of patient, or the signature of representative who accepted the delivery, or indication of COVID-19 if appropriate
- If Mailing:
- The COVID-19 pandemic had many PBMs make concessions to allow mailing during the Public Health Emergency (PHE). Keep up to date on concession expirations by downloading our COVID-19 PBM/Payers Concessions Chart
- The current COVID-19 PHE will expire 5/11/2023. See our article in next month’s Newsline for further considerations/implications.
- If you are mailing out of state, be sure to check that state’s Board of Pharmacy to see if there are licensing requirements
- PBMs that allow mailing will require proof that the patient received the medication and what was in the package
- A tracking number linked to the prescription record along with tracking detail from the carrier showing the medication was delivered is traditionally sufficient
- Be familiar with automatic mailing requirements for Part D patients, review the September 2022 Newsline article, Automatic Mailing for Part D Patients
- Read the November 2022 Newsline article, Yes, LTC Delivery Manifests ARE Needed!
- The PAAS Trifold Signature Log Mailer is available for use on the PAAS Member Portal
- If Medicare B DMEPOS Proof of delivery:
- For in store pick-ups, the delivery date (date received) must match the date of service
- For items delivered via a shipping service or mail, the date of service can be either the shipping date or delivery date
- Read the June 2021 Newsline article, DMEPOS Proof of Delivery and Refill Request Requirements
- Pharmacies using manual signature logs may want to consider ordering the PAAS National® Signature Logbook
- Consult with your software vendor on updating your delivery/signature logs to include a signature date
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