Automatic Prescription Refill Concerns

• Participants receiving medications that were discontinued months prior;
• Multiple strengths of the same medication when the prescriber changed doses but the pharmacy continued to autofill both;
• Multiple products in the same drug class when the prescriber changes medications, but the pharmacy fills the old and the new medication; and
• Pharmacies filling “as needed” medications each month, including migraine medications, rescue inhalers, and COVID tests, among others.

Unfortunately, PAAS National^® has assisted with audits where the PBM is requesting proof of refill request. They required pharmacies to have a system in place to document that a patient requested a refill and note the date of request. Some of these audits were for Medicaid plans, some were simply audits where the patient had denied requesting the medication be filled possibly due to the patient misunderstanding the request by the PBM. In these cases, it is up to the pharmacy to prove that they filled the medication in accordance with a patient’s wishes.

PAAS Tips:

• Be aware, state pharmacy regulations may prohibit, or require additional documentation for, automatic refill programs
• Medicare B requires Proof of Refill Request for supplies that are mailed and delivered, to confirm patient need and proof of exhaustion for previous supplies
  • Contact PAAS if you need a template
• Avoid putting bulk items like inhalers, insulin, eye drops or topicals on med sync
• Do not put “as needed” or controlled substance medications on med sync
• Ensure the refill interval is at ≥ 90% utilization
• If employing a med sync program, review our August 2022 Newsline article, Medication Synchronization: Possible Concerns
• Read the September 2022 Newsline article, Automatic Mailing for Part D Patients, for more information