Audit and Appeal Due Dates: Stay Ahead of the Clock with These Essential Tips

Pharmacy practice often revolves around meeting tight deadlines. Prioritizing can become challenging when you’re focused on providing prompt service to waiting patients or rushing to meet inventory ordering deadlines, all while managing your daily tasks. It’s tempting to push aside a PBM audit request, or its results, to tackle more immediate responsibilities. Unfortunately, neglecting audit or appeal due dates can lead to significant, and unnecessary, financial losses to the PBMs.

One of PAAS National®’s top priorities is helping pharmacies navigate the audit process successfully from start to finish. Remember to engage PAAS early by submitting your audit notice or audit results as soon as you receive them. Discussing your audit notice or results with your assigned analyst early can help you avoid unnecessary work when putting documentation together. This can also eliminate providing unnecessary information to auditors.

A great way to begin is by establishing a workflow process when audits are received. The following tips can assist you with a more efficient and effective audit outcome.

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Step 1: Audit Notice or Audit Results Received

  • Dedicate a specific area for audit documents and inform pharmacy staff of what to do when audit notices are received
  • Send your audit notice or audit results to PAAS as soon as you receive them
  • Discuss with your PAAS analyst the appropriate documents needed for response
  • Contact an auditor/PBM as soon as possible if you feel an extension may be needed
  • Set calendar reminders for audit and appeal due dates

Step 2: Prepare your Documents

  • Gather documents and organize in order of audit request
  • Always number your pages for easier reference for you, your PAAS analyst, and the auditor
  • When signature logs are requested on a separate list, keep those separate in your documents

Prescription Documents

  • While many audits request multiple dates of fill, only one prescription hardcopy is necessary for each Rx#
  • When printing electronic images of prescriptions, be sure to include any electronic clinical notations in your system for auditor to view
  • Reminder all clinical notes should include:
    • Date
    • Name and title of agent you spoke with
    • Specific information that was provided
    • Initials of pharmacy employee that made the call
  • Include any supporting documentation for DUR or SCC overrides
  • When backtags or labels are requested, these can be added to the same page as the prescription
  • Be sure backtags or labels do not cover any prescription elements
  • Keep backtags or labels in same orientation as prescription
  • Unless otherwise indicated, redact any pricing information

Signature/Delivery Requests

  • Always confirm if audit is requesting signature/delivery logs
  • Signature/delivery logs must include:
    • Rx number
    • Date of fill (or fill number)
    • Date dispensed
    • Patient/patient representative signature
  • Redact any PHI not on audit request

Proof of Copay Collection

  • Proof of copay collection is only needed when an audit specifically requests
  • Point-of-Sale transactions, register receipts, or A/R account invoices showing how payment was made may be necessary for responses
  • When secondary payors are involved, be sure to include claims data

Step 3: Submitting your Audit

  • Audit requests provide specific instructions on how to submit your documents
  • While faxing is typically an option, sending large audits this route is generally not advisable
  • Sending via secure email or uploading to a portal are the best recommendations

Step 4: Audit Outcome

  • Keep eyes open for audit results and inform staff of what to do when results are received
  • Set calendar reminder to follow up on audit status when results are not received on a timely basis
  • Remember, checking on your audit results will not change their outcome and may prevent you from missing an appeal deadline

Audit Results and Appeal

  • Audit appeals are individualized for each PBM and discrepancy
  • Review results closely for appeal deadlines as these vary per PBM
  • Involve your PAAS analyst right away as appeal documentation may take additional time and effort to obtain
  • Sending in your appeal documentation for your analyst review can be very helpful to identify any missing or incorrect information

PAAS Tips:

  • Send your audit notice or audit results to PAAS right away
  • Follow the PAAS National® guidance for Getting Help with an Audit
  • Submit audit notice, results or documents for review by uploading to our portal, faxing or emailing
  • When sending electronically, be sure to send as one aggregated file with numbered pages
  • If you send multiple attachments via fax or email, be sure each attachment is clearly labeled
  • Consult our Call Center if you need assistance with submitting your documents
  • Keep your PAAS analyst engaged on any updates or additional requests for your audit
  • Consider training additional staff to assist with your audits as a back up

Dana Westberg, CPhT