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 and PBM requirements. Staff are not able to retroactively complete 2025 training in 2026. Auditors, especially those visiting on-site, routinely request proof of FWA and HIPAA training for all staff. Non-compliance can result in contract termination, so take action now to ensure your pharmacy avoids this risk.
FWA and HIPAA Training: All employees involved in the filling, billing, dispensing or delivery of Medicare and/or Medicaid prescriptions are required to complete FWA training within 30 days of hire (per PBM requirements) and at least once per year thereafter. The training itself should cover FWA and General Compliance topics and must include details outlining your pharmacy’s specific policies and procedures for how you prevent, detect, and correct FWA. Training and education for employees includes the CEO, senior administrators, and managers as per CMS Chapter 9.50.3. Since interns, float staff, cashiers and delivery drivers are involved in daily pharmacy operations such as billing, filling, counseling, dispensing, delivery of services and/or other professional services, they must also complete FWA training.
Safeguarding the pharmacy’s PHI is mandatory for all staff who may come into contact with this sensitive data (including cashiers and delivery drivers). Requiring HIPAA training before interns, job shadows, or floating pharmacy staff are allowed behind the pharmacy counter helps ensure they understand proper safeguards and the serious consequences (including civil monetary penalties and criminal consequences) of improperly disclosing PHI. Additionally, if an employee has access behind the pharmacy counter, they need to be HIPAA trained.
Pharmacy staff who are contracted to deliver medications for your pharmacy, work on a temporary basis or simply float through your store are also subject to FWA and HIPAA training requirements. Whether these employees are hired directly by your pharmacy (or paid through a 1099), or they are contracted through a third-party staffing company, the burden is on the pharmacy owners/operators to ensure all members of their staff have received appropriate training.
The PAAS National® FWA/HIPAA Compliance Program membership includes educational presentations and comprehension quizzes through the Member Portal. Current FWA/HIPAA Compliance Program members should log in and ensure their 2025 training is complete.
- All employees must complete the 2025 FWA Modules 1-4
- All employees must review and sign the Employee Compliance Training Handbook Acknowledgement as well as the Code of Conduct
- Account administrators should have received an email notification in mid-October if any of their employees have incomplete quizzes or missing signatures and will receive one to two more email reminders from PAAS before the end of the year if any quiz or signature remains incomplete
Cultural Competency Training: When completing your annual profile credentialing through the NCPDP website, pharmacies must indicate whether they train their staff on cultural competency. By answering “yes” the pharmacy attests to training their staff and to maintaining documented evidence of such training. An answer of “no” may lead to PBMs excluding your pharmacy from their list of providers offering culturally competent care (a requirement for Medicaid managed care plan directories). More information about this training can be found in the May 2024 Newline article and within the On-Demand Webinar, both titled Does My Pharmacy Really Need Cultural Competency Training? Both resources speak to the importance of this training as well as federal laws and regulations related to discrimination and cultural competency requirements for healthcare professionals.
Cybersecurity Training: The dynamic nature of cyberthreats necessitates continual adaptation and vigilance. Cybersecurity training helps equip staff with essential knowledge regarding best practices to hinder potential threats related to network connected medical device security, insider data loss, loss or theft of equipment and data, ransomware, and social engineering. Threats lurk around every digital corner and safeguarding sensitive information has never been more crucial. That is why PAAS added Cybersecurity training (starting in 2024) to the FWA/HIPAA Compliance Program Membership package at no additional cost!
USP 800 Compliance Training: USP 800 is not just for compounding pharmacies! Exposure to hazardous drugs (HDs) extend to everyone working in the pharmacy, from the pharmacists and pharmacy technicians who handle HDs, to those who work at the pharmacy counter or in the receiving and delivery areas. The key is developing good practices to contain or reduce risk. Per OSHA, the safe handling of HDs in accordance with USP 800 is considered a “national professional standard” as a pharmacy process “to protect the safety and health of employees”. A USP 800 compliance program is a necessary step to protect the health and safety of employees, patients in the pharmacy, and the environment. It can also help reduce employer liability from frivolous lawsuits through employee training, competency documentation and employee acknowledgements.
Contact PAAS for more information on how we can help you reach your compliance requirements.
AstraZeneca/Farxiga® Letters—Round 2 Hitting Pharmacies
Pharmacies across the country are receiving a second notice from AstraZeneca regarding Farxiga® discrepancies. As before, there are two versions of this letter but now AstraZeneca is asking pharmacies for specific information and actions.
Did you know there is much more to your audit assistance membership than just help with audits? The PAAS Member Portal contains a wealth of information and resources to assist you with audits and member service questions. Below is a list of 6 pages found on the Audit Assistance section of the PAAS Member Portal to assist you and your pharmacy staff to be proactive when it comes to audits.
PAAS Tips:
Retail Playbook in LTC Audits: More Alike Than Different
While the day-to-day operations of an LTC pharmacy may be drastically different from retail pharmacies, auditors frequently treat them the same, especially when it comes to documentation requirements.
Did you know there is much more to your audit assistance membership than just help with audits? The PAAS Member Portal contains a wealth of information and resources to assist you with audits and member service questions. Below is a list of 6 pages found on the Audit Assistance section of the PAAS Member Portal to assist you and your pharmacy staff to be proactive when it comes to audits.
PAAS Tips:
Using SCC 13 Correctly: Protecting Claims in Disaster Situations
Pharmacies serve a vital role in supporting their communities, especially when patients face disruptions during natural disasters. In such events, access to essential medication can be compromised. While helping patients through these challenging times, ensure that your pharmacy’s claims remain protected by confirming staff understand which override(s) to use and how to apply them correctly.
Did you know there is much more to your audit assistance membership than just help with audits? The PAAS Member Portal contains a wealth of information and resources to assist you with audits and member service questions. Below is a list of 6 pages found on the Audit Assistance section of the PAAS Member Portal to assist you and your pharmacy staff to be proactive when it comes to audits.
PAAS Tips:
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 and oddities which must be corrected prior to billing. These corrections and/or clarifications are often critical to the payment of the claim. To ensure an auditor will accept the clarification…
Did you know there is much more to your audit assistance membership than just help with audits? The PAAS Member Portal contains a wealth of information and resources to assist you with audits and member service questions. Below is a list of 6 pages found on the Audit Assistance section of the PAAS Member Portal to assist you and your pharmacy staff to be proactive when it comes to audits.
PAAS Tips:
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 and PBM requirements. Staff are not able to retroactively complete 2025 training in 2026. Auditors, especially those visiting on-site, routinely request proof of FWA and HIPAA training for all staff. Non-compliance can result in contract termination, so take action now to ensure your pharmacy avoids this risk.
FWA and HIPAA Training: All employees involved in the filling, billing, dispensing or delivery of Medicare and/or Medicaid prescriptions are required to complete FWA training within 30 days of hire (per PBM requirements) and at least once per year thereafter. The training itself should cover FWA and General Compliance topics and must include details outlining your pharmacy’s specific policies and procedures for how you prevent, detect, and correct FWA. Training and education for employees includes the CEO, senior administrators, and managers as per CMS Chapter 9.50.3. Since interns, float staff, cashiers and delivery drivers are involved in daily pharmacy operations such as billing, filling, counseling, dispensing, delivery of services and/or other professional services, they must also complete FWA training.
Safeguarding the pharmacy’s PHI is mandatory for all staff who may come into contact with this sensitive data (including cashiers and delivery drivers). Requiring HIPAA training before interns, job shadows, or floating pharmacy staff are allowed behind the pharmacy counter helps ensure they understand proper safeguards and the serious consequences (including civil monetary penalties and criminal consequences) of improperly disclosing PHI. Additionally, if an employee has access behind the pharmacy counter, they need to be HIPAA trained.
Pharmacy staff who are contracted to deliver medications for your pharmacy, work on a temporary basis or simply float through your store are also subject to FWA and HIPAA training requirements. Whether these employees are hired directly by your pharmacy (or paid through a 1099), or they are contracted through a third-party staffing company, the burden is on the pharmacy owners/operators to ensure all members of their staff have received appropriate training.
The PAAS National® FWA/HIPAA Compliance Program membership includes educational presentations and comprehension quizzes through the Member Portal. Current FWA/HIPAA Compliance Program members should log in and ensure their 2025 training is complete.
Cultural Competency Training: When completing your annual profile credentialing through the NCPDP website, pharmacies must indicate whether they train their staff on cultural competency. By answering “yes” the pharmacy attests to training their staff and to maintaining documented evidence of such training. An answer of “no” may lead to PBMs excluding your pharmacy from their list of providers offering culturally competent care (a requirement for Medicaid managed care plan directories). More information about this training can be found in the May 2024 Newline article and within the On-Demand Webinar, both titled Does My Pharmacy Really Need Cultural Competency Training? Both resources speak to the importance of this training as well as federal laws and regulations related to discrimination and cultural competency requirements for healthcare professionals.
Cybersecurity Training: The dynamic nature of cyberthreats necessitates continual adaptation and vigilance. Cybersecurity training helps equip staff with essential knowledge regarding best practices to hinder potential threats related to network connected medical device security, insider data loss, loss or theft of equipment and data, ransomware, and social engineering. Threats lurk around every digital corner and safeguarding sensitive information has never been more crucial. That is why PAAS added Cybersecurity training (starting in 2024) to the FWA/HIPAA Compliance Program Membership package at no additional cost!
USP 800 Compliance Training: USP 800 is not just for compounding pharmacies! Exposure to hazardous drugs (HDs) extend to everyone working in the pharmacy, from the pharmacists and pharmacy technicians who handle HDs, to those who work at the pharmacy counter or in the receiving and delivery areas. The key is developing good practices to contain or reduce risk. Per OSHA, the safe handling of HDs in accordance with USP 800 is considered a “national professional standard” as a pharmacy process “to protect the safety and health of employees”. A USP 800 compliance program is a necessary step to protect the health and safety of employees, patients in the pharmacy, and the environment. It can also help reduce employer liability from frivolous lawsuits through employee training, competency documentation and employee acknowledgements.
Contact PAAS for more information on how we can help you reach your compliance requirements.
What Is a Targeted Probe and Educate Audit?
CMS rolled out the Targeted Probe and Educate (TPE) program back in 2017. The goal of the TPE program is to help providers reduce the number of DMEPOS claim denials by using data analysis and providing one-on-one educational sessions to avoid common mistakes. DME Medicare Administrative Contractors (MACs) analyze data to identify providers who have the highest claim denial rates or who have billing practices that vary significantly from their peers. Please see the tips below to follow the steps of a TPE audit.
PAAS Tips:
Did you know there is much more to your audit assistance membership than just help with audits? The PAAS Member Portal contains a wealth of information and resources to assist you with audits and member service questions. Below is a list of 6 pages found on the Audit Assistance section of the PAAS Member Portal to assist you and your pharmacy staff to be proactive when it comes to audits.
PAAS Tips:
Billing Considerations That Will Save You Later
Filing and billing claims involves keeping track of what can feel like an endless number of details. The fast-paced environment of the pharmacy doesn’t always allow for keeping tedious details at the forefront of your mind. Below you’ll find a guide detailing common scenarios that should be considered while filling prescriptions to reduce your audit risk.
Did you know there is much more to your audit assistance membership than just help with audits? The PAAS Member Portal contains a wealth of information and resources to assist you with audits and member service questions. Below is a list of 6 pages found on the Audit Assistance section of the PAAS Member Portal to assist you and your pharmacy staff to be proactive when it comes to audits.
PAAS Tips:
The $40 Incentive Fee You Might Be Missing!
Since 2021, a program created by CMS has allowed eligible pharmacies to receive additional reimbursement for administering the COVID-19 vaccine to certain Medicare homebound patients.
Did you know there is much more to your audit assistance membership than just help with audits? The PAAS Member Portal contains a wealth of information and resources to assist you with audits and member service questions. Below is a list of 6 pages found on the Audit Assistance section of the PAAS Member Portal to assist you and your pharmacy staff to be proactive when it comes to audits.
PAAS Tips:
Billing Ozempic® 0.25 mg Weekly as a Maintenance Dose – What is the Big Deal?
PAAS National® analysts field many questions on Ozempic® relating to off-label use; however, we also receive questions about what days’ supply to submit on claims – particularly for initiation dosing. Section 2.2 of the manufacturer package insert (available on DailyMed) lists the recommended dosage schedule based on clinical trials and includes the following titration schedule:
Pharmacies often see prescribers write for Ozempic® 0.25 mg weekly as a maintenance dose. What days’ supply should the pharmacy transmit?
Did you know there is much more to your audit assistance membership than just help with audits? The PAAS Member Portal contains a wealth of information and resources to assist you with audits and member service questions. Below is a list of 6 pages found on the Audit Assistance section of the PAAS Member Portal to assist you and your pharmacy staff to be proactive when it comes to audits.
PAAS Tips:
Easy Pickings: Why Transferred Prescriptions are Audit Bait
Transferring prescriptions into your pharmacy is usually great for business; however, pharmacies must be aware of the additional audit risks with these prescriptions. PBM audit algorithms easily identify transfers due to the origin code of 5 being submitted during claim adjudication.
Each state has requirements put in place by their pharmacy board that outline what information must be obtained and documented when transferring a prescription. These requirements differ from state to state, so be sure to educate staff on the state specific elements. Missing even one small piece of information can result in a recoupment during an audit.
One common mistake pharmacies make…
Did you know there is much more to your audit assistance membership than just help with audits? The PAAS Member Portal contains a wealth of information and resources to assist you with audits and member service questions. Below is a list of 6 pages found on the Audit Assistance section of the PAAS Member Portal to assist you and your pharmacy staff to be proactive when it comes to audits.
PAAS Tips: