Entries by Eric Hartkopf, PharmD

Hidden Risks in Online Marketplace Drug Purchasing: What Pharmacies Need to Know

May 20, 2026

The rise of online pharmaceutical marketplaces has introduced new efficiencies for pharmacies seeking to manage inventory, control costs, and address drug shortages. These platforms often promise competitive pricing, expanded sourcing options, and rapid fulfillment. However, they also introduce a significant, and often underappreciated, risk: the potential for suspect or counterfeit product entering the pharmacy supply […]

Two NDCs, One Fill: Best Practices for Pharmacies  

May 2, 2026

Pharmacies frequently find themselves piecing together a prescription using leftover inventory from an old NDC and a new [equivalent] NDC to finish the fill—often due to wholesaler preferred status changes, drug availability, discontinued products, or changing purchasing preferences. Using two NDCs on a single prescription introduces significant dispensing and billing risks, and if not handled […]

PBM Audit Risk When Purchasing Inventory from a Closing Pharmacy

April 28, 2026

When a pharmacy purchases remaining prescription drug inventory from a closing pharmacy, what may seem like a straightforward transaction can introduce complex documentation gaps and challenges—ultimately increasing exposures to downstream PBM audit risk. While such transfers are often permissible under state law and the Drug Supply Chain Security Act (DSCSA), PBM auditors frequently scrutinize non-wholesaler […]

Prior Authorization Support: Strategies to Mitigate Audit Risks

April 10, 2026

Prior authorization (PA) requirements imposed by PBMs have become a major administrative barrier to medication access. To help reduce delays and improve patient outcomes, some pharmacies are assisting prescribers by submitting prior authorizations on their behalf. While these services can benefit patients and strengthen relationships between pharmacies and prescribers, they also introduce important compliance and […]

Medicare Transaction Facilitator (MTF) Updates

February 20, 2026

We are now one month into 2026, and pharmacies are feeling the impact of the Medicare Part D Drug Price Negotiation Program (MDPNP). Hopefully your pharmacy is getting more comfortable …

$300,000 Settlement for Employing Excluded Individual

February 14, 2026

The U.S. Attorney’s Office for the District of New Hampshire recently announced a $300,000 settlement with a telehealth company and its owner to resolve allegations of improper Medicaid billing under the False Claims Act. The government alleged that the company billed Medicaid for services provided by an individual who was excluded from participation in federal […]

OIG Report: Medicare Payments for Continuous Glucose Monitors

January 29, 2026

A recent OIG report found that Medicare may be overpaying suppliers for Continuous Glucose Monitors (CGMs) and supplies relative to other payers. The report highlighted the following: As a result of the findings, OIG has recommended that CMS reduce payments for CGMs and supplies and address improper use of billing codes to reduce overpayments. CMS […]

Eye Drop Chart Updates

January 23, 2026

PAAS National®® analysts have identified a recent trend of audit enforcement related to days’ supply for eye drops, with a particular focus from Prime Therapeutics. Most PBMs provide a “drops per mL” estimate in their provider manual, but they often provide a qualifier that pharmacies should use the PBM estimate “unless otherwise indicated by the […]