Entries by Sara Hathaway, PharmD

2026 PAAS Fraud, Waste & Abuse and HIPAA Compliance Program Updates

PAAS National®® continuously monitors legislative and regulatory changes that may impact your Fraud, Waste & Abuse and HIPAA Compliance Program. We keep a close eye on enforcement from the Department of Justice, Office of Inspector General, State Attorney Generals, and Office for Civil Rights to help ensure the program meets interpretative standards. Furthermore, PAAS works […]

The Audit Risk at The Tips of Your Fingers (and Toes!)  

Antifungal nail treatments remain a high audit target. If the pharmacy is dispensing Jublia® (efinaconazole), ciclopirox (formerly Penlac®), or tavaborole (formerly Kerydin®), you can almost guarantee you’ll see that claim show up on an audit. Auditors love these medications because if the prescription does not clearly indicate…

HIPAA Breach in 2025? Notification to HHS is Required

What is significant about March 1, 2026? According to the website Days Of The Year, it is National Barista Day, Share a Smile Day, and Endometriosis Awareness Day. While these are all great causes, the date carries additional significance for any covered entity (e.g., a pharmacy) who had a HIPAA breach of less than 500 […]

Avoiding TPE Audit Denials: Guidance for Medicare Part B Nebulizer Solution Claims

Recently, PAAS National®® analysts have been assisting pharmacies with Targeted Probe and Educate (TPE) audits from CGS, the DME Medicare Administrative Contractor (MAC) for Jurisdictions B and C. Per CGS, “The purpose of the claim review is to ensure documentation supports the reasonable and necessary criteria of the services billed and follows Medicare rules and […]

Making Prescription Annotations Audit-Ready

In a perfect world, all prescriptions received by your pharmacy would be 100% accurate with no need to follow up with the prescriber for clarification. Since we do not live in that utopian paradise, it is a common occurrence that prescriptions come over with invalid or non-specific quantities, incomplete or unclear directions, or other errors […]

Time is Running Out! Is Your 2025 Training Complete?

As the year winds down, it is important to verify that all staff have completed their required training. Once the clock strikes midnight on December 31st, all 2025 training requirements must be completed. If the pharmacy has staff who have not completed their training by this deadline, the pharmacy will be considered non-compliant with CMS […]

Compliance Check: Is Your Authority to Vaccinate Still Valid?

Vaccine season is upon us! Pharmacies who offer immunization services are likely seeing an influx in requests for seasonal influenza, COVID-19, and other routine vaccines. However, it is important to take a step back and evaluate exactly which vaccines you are formally allowed to authorize and administer, especially after the meeting of the Advisory Committee […]

Real-World Examples of Fraud, Waste & Abuse and Audit Implications

It is no secret that margins are thin and pharmacies have been looking for additional revenue-generating opportunities. Some pharmacies have added immunization services, performed billable Medication Therapy Management, added Point of Care Testing, and/or found other non-PBM income sources to offset low (or negative) reimbursements from third-party payors. These services are patient-focused and can increase […]

Empowering Pharmacy Teams to Decrease Audit Risk

Sir Francis Bacon is often credited with stating “scientia potentia est” in his published work, Meditationes Sacrae from 1597. This Latin phrase roughly translates to “knowledge is power” and while this turn of phrase is centuries old, it holds true today. The pharmacy industry is an ever-changing world and staying up to date on audit […]

New DUR Codes for Insulin Method of Administration

If your pharmacy dispenses rapid-acting insulin, be ready to start closely evaluating the patient’s method of administration. Knowing whether a patient is using the rapid-acting insulin for direct injection (via syringe or pre-filled pen), with a disposable insulin pump, or in a qualifying DME pump will become critical to claim payment starting in October.