Entries by Eric Hartkopf, PharmD

Medicare Drug Price Negotiation: MTF Data Module Enrollment & Caremark Attestation

Starting in 2026, Medicare has negotiated the price of 10 brand drugs under the Medicare Drug Price Negotiation Program as part of the Inflation Reduction Act of 2022. The negotiations between CMS and drug manufacturers have resulted in Maximum Fair Prices (MFPs). To implement this program, CMS has created the Medicare Transaction Facilitator (MTF) which […]

USP 800: What Community Pharmacies Need to Know

Most community pharmacies don’t compound with hazardous drugs, but that doesn’t mean you’re off the hook when it comes to USP 800 compliance. This standard, USP General Chapter <800> Hazardous Drugs: Handling in Healthcare Settings, applies to anyone who receives, stores, or dispenses hazardous drugs (HDs). And yes, that includes community pharmacies. What Makes a […]

Where Can I Find PBM Provider Manuals?

Each PBM has their own unique set of “rules” for network pharmacies to follow, and they publish these rules in their Provider Manual. Pharmacies should be aware these Provider Manuals are an extension of the Provider Agreement and contractually obligate pharmacies to adhere to these requirements. To make matters worse, PBMs update these manuals at […]

Caremark LTC Override Code Audits

Caremark frequently issues desk audits, labeled as LTC Override Code Audits, to validate certain override codes that allow LTC pharmacies to process claims without having to call the helpdesk (generally due to early refill rejections). Submission Clarification Codes (SCC) may be input by pharmacies into NCPDP field 420-DK to identify unique dispensing situations such as […]

CERT Improper Payment Rates: DMEPOS

Each fiscal year, the Department of Health and Human Services (HHS) publishes improper payment rates for Medicare FFS Part A, Part B, and DMEPOS claims submitted between July 1 and June 30. These error rates are determined through Comprehensive Error Rate Testing (CERT) audits of a stratified, randomized sample of claims across various provider types […]

Dexcom G6/G7 Sensors: Retail vs DME

PAAS National®® analysts have received numerous calls from pharmacies related to continuous glucose monitor (CGM) products made by Dexcom, particularly the G6/G7 sensors. There appears to be two different versions of Dexcom products – those labeled for “Retail” (pharmacy benefit) and those labeled for “DME” (medical benefit). Pharmacies report finding both products on wholesaler websites […]

COVID-19 Vaccine Update: Shared Clinical Decision-Making

The CDC recently revised recommendations for COVID-19 vaccination by (i) removing the recommendation for pregnant women to receive the vaccine and (ii) that individuals ages 6 months to 17 years may receive the vaccine using a shared clinical decision-making (SCDM) approach. The SCDM recommendations are meant to be flexible and informed by the characteristics, values, […]

AstraZeneca Letters re: Farxiga® Data Discrepancies

Numerous pharmacies have received letters from AstraZeneca, the manufacturer of Farxiga® 5 and 10 mg, regarding “discrepancies” identified in a reconciliation of purchase and dispensing data from 2024.

OIG Semiannual Report to Congress Shows 11:1 Return On Investment

The Department of Health and Human Services (HHS) Office of Inspector General (OIG) recently released its Semiannual Report to Congress summarizing program integrity efforts from October 2024 through March 2025 which showed a return of $11 for every $1 spent. The OIG is the lead federal agency combating healthcare fraud, waste, and abuse in federal […]