Entries by Eric Hartkopf, PharmD

West Coast Strike Force Launched to Target Health Care Fraud

The U.S. Department of Justice has announced a new West Coast Health Care Fraud Strike Force focused on investigating and prosecuting health care fraud in Arizona, Nevada, and Northern California. The initiative brings together federal prosecutors and agencies including the DOJ, FBI, DEA, and HHS-OIG to aggressively target fraud involving Medicare, Medicaid, TRICARE, and private […]

Low-Income Subsidy (LIS) Dual-Eligible Copay Reconciliation

PAAS National®® analysts have recently assisted numerous pharmacies with letters from PBMs regarding copays for medications dispensed to dual eligible (Medicare Part D and Medicaid) patients within the last few months.

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

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  

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

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

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

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

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 […]