Partially dispensing prescriptions is a common, and practical, approach used in pharmacy practice to ensure patients receive timely access to medications when the full prescribed quantity is not immediately available. Rather than delaying therapy, a pharmacy may dispense a portion of the medication and provide the remaining balance at a later time.
Partial dispensing most often occurs because of inventory shortages, wholesaler delays, or even manufacturer backorders. Regardless of the reason, the pharmacy’s primary goal is to prevent interruptions in therapy, especially for medications that are critical to a patient’s health.
As many independent pharmacies know, onsite audits are often the most stressful, and contentious, audit type. Beyond prescription documentation, auditors are known to ask for various policies and procedures, frequently requesting a partial fill/dispensing policy. Because of the circumstances [of an onsite audit], pharmacies are leery about saying the wrong thing.
With partial dispensing, …
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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.
- Access Services
- Audit Documentation Submission Guidance
- An online form to submit safe filling and billing questions
- Your PAAS Membership Manual
- Newsline
- Monthly newsletter articles, written by our expert PAAS analyst team, provide safe filling and billing tips and relays relevant/current PBM trends to be help prevent audits
- Search the Newsline Archive to get PAAS tips at the click of a button
- Special Edition Newslines including: Top 10 articles of the prior year, DMEPOS Article Series and a Self-Audit Article Series
- Ability to print monthly issues or individual articles
- Proactive Tips
- Audit flags – list of various claim attributes the PBMs use to select claims for audit
- Billing insulin vials – flowchart to assist whether you should bill Medicare Part B vs Part D
- DAW Codes Explained – use to understand when to effectively use DAW codes, their definitions and why claims may be flagged for audit if a DAW code is used incorrectly
- Basic DMEPOS documentation guidance
- Onsite Credentialing Checklist and expanded definitions of policies and procedures
- Proof of refill request and affirmative response form for DMEPOS items
- Steps on how to prepare for an onsite audit
- And more!
- Days’ Supply Charts
- Utilize the days’ supply charts for inhalers, insulins, nasal sprays, eye drops and topicals to aid you in calculating the correct days’ supply
- Guidance on overbilled quantities and incorrect days’ supply account for a sizable portion of audit chargebacks
- Additional miscellaneous charts, which include: Dispense in Original Container and Return to Stock
- Forms
- Signature Logbook for print
- Signature Trifold Mailer
- Fax and Email Coversheet
- Patient Attestation for over-the-counter COVID-19 test kits
- On-Demand Webinars
- Short webinars on hot topics in the PBM industry. Here are a few examples:
- USP 800 Compliance
- Cultural Competency Training
- Dispensing Prescriptions Off-Label
- Biologic Medications and Interchangeability
- Continuous Glucose Monitor Requirements for Medicare Part B
PAAS Tips:
- MORE AUDITS, MORE INSIGHT – PAAS National® is the industry-leading defender of community pharmacy dealings with Prescription Benefit Programs, including Caremark, Express Scripts, Humana, Medicaid, OptumRx, Prime Therapeutics., and more. PAAS assists on all third-party audits, including: desktop audits, onsite audits, invoice audits, OIG/Medicaid audits, Medicare B audits. The PAAS team is dedicated to helping you! We have five pharmacists and a complement of technician analysts with over 50 years of dedicated audit assistance experience. PAAS continuously updates their database with every audit received — in fact, we even keep a scorecard on individual auditors.
- Get answers to your questions on days’ supply calculations, drug substitutions, billing practices, required documentation, prior authorization requirements, record retention, and internal audit procedures – just to name a few. As a trusted partner, we will provide tailored guidance to help you proactively prevent audits. Remember, the prescription claims you submit today are the audits of the future.
- Keep your employees engaged and help lower audit risk by adding all employees to the portal and giving them permission to access these tools, resources and eNewsline. For more information review September 2019 Newsline article, What Are You Waiting For? Make Sure ALL of Your Employees are Added to the PAAS Portal!
- Contact PAAS at (608) 873-1342, if you would like a tour of your PAAS Member Portal, so you can reap all the benefits of your PAAS Audit Assistance. We appreciate you being a member.
How to Avoid the Vaginal Cream Recoupment Domino Effect
Estrace® and Premarin® vaginal creams continue to be audit targets because they are often found to be billed incorrectly. A recovery on one claim billed with a wrong days’ supply often causes subsequent refills to be recouped for being ‘refilled too soon’. To prevent this claim recoupment…
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:
Pharmacist Sentenced to 80 Months in Prison
According to a press release from the Department of Justice (DOJ), a Michigan pharmacist was sentenced to 80 months in prison for committing health care fraud. The pharmacist’s scheme consisted of billing health care benefit programs for prescription medications that were ultimately never dispensed. From 2019 through 2022, the pharmacist and his co-conspirator used forged prescriptions from providers to conceal their fraudulent scheme; however, there was no record of these patients ever seeing the prescribers indicated on the forged prescriptions.
Together, these two perpetrators caused over $6 million in losses to health care benefit programs like Medicare, Medicaid, and Blue Cross Blue Shield of Michigan. The pharmacist pleaded guilty to one count of conspiracy to commit health care fraud. In addition to being sentenced 80 months in prison, the pharmacist was ordered to pay $3,889,760 in restitution and $3,230,147 in forfeiture, including his interest in approximately $1.2 million of fraudulent proceeds seized by law enforcement.
PAAS Tips:
Preventing Substitution Errors Among Interchangeable Denosumab Biosimilars
Many pharmacies are familiar with Prolia® (denosumab) for the treatment of osteoporosis in women after menopause who are high risk for fracture or cannot use another osteoporosis medication (or the other medications weren’t efficacious). There is another denosumab product (brand name Xgeva®) approved for bone problems due to cancer. Prolia® and Xgeva® are not …
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:
Improving Accuracy and Efficiency: Rx Days’ Supply Calculator Adoption Grows
Nearly one thousand pharmacy professionals now rely on the Rx Days’ Supply Calculator to help address the ongoing challenges of manually calculating the appropriate quantity or days’ supply of medications, saving time and reducing errors while simultaneously decreasing the risk of PBM audits. The Rx Days’ Supply Calculator app is a tool designed to simplify calculations for pharmacists and pharmacy technicians.
The PAAS Rx Days’ Supply Calculator offers a user-friendly interface designed to enhance efficiency and empower pharmacy staff with confidence:
We invite you to be proactive and experience the benefits of the PAAS Rx Days’ Supply Calculator today! The app is available with a FREE 7-day trial, followed by an annual subscription of $5.99, and can be accessed by visiting the Apple App Store or Android Google Play Store, or check out the website at PAASNational.com/app.
Isotretinoin Therapeutic Equivalence and iPLEDGE® REMS Documentation Alert
According to the FDA labeling, isotretinoin capsules are indicated for the treatment of severe recalcitrant nodular acne in non-pregnant patients 12 years of age and older with multiple inflammatory nodules with a diameter of 5 mm or greater.
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:
Creon Claims at Risk: OptumRx Audit Recoupments Continue
OptumRx continues to focus on medications with special dispensing requirements. Creon® has ranked among the top five medications requested through OptumRx prescription validation requests for the past three years and that trend is continuing into 2026. Although the PBM characterizes these reviews as prescription validation requests rather than desk audits, PAAS National® analysts consistently see pharmacies with claim recoupments resulting from both when Creon …
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:
Diabetic Test Strip Authorized Distributors
Independent pharmacies continue to receive threatening letters regarding the purchase of LifeScan OneTouch® test strips.
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:
OIG & DOJ Doubling Down on Health Care Fraud
The Office of Inspector General (OIG) announced a work plan being initiated for ‘bad actor’ pharmacies (previously identified by CMS or Part D Plan Sponsors) that continue to bill and receive payment for Part D drugs. OIG has concerns that existing CMS enforcement tools, such as revocation, preclusion, and payment suspension, may not effectively deter fraudulent pharmacies from billing Part D plans. The review aims to assess whether pharmacies identified as bad actors continue to bill and receive Part D payments and to identify opportunities for CMS and Part D plan sponsors to strengthen fraud detection and prevention efforts.
Not long after the OIG’s announcement, the U.S. Department of Justice (DOJ) released a report revealing a record-setting $6.8 billion in False Claims Act recoveries in fiscal year 2025. This is the highest annual recovery in the statute’s history, reflecting the intensified enforcement efforts for fighting fraud against the federal government. Health care fraud continues to yield the most recovery in these efforts.
Prescription drugs remained a major focal point, with allegations leading to a nearly $1 billion judgment against a pharmacy. Pharmaceutical manufacturers also faced significant scrutiny, resulting in more than $660 million in settlements tied to alleged copay kickbacks and speaker programs. Additional takeaways from the report include:
Notably, self-disclosure and cooperation resulted in several settlements reflecting credits (resulting in reduced payments) for parties who self-reported misconduct, assisted in investigations, and/or implemented remedial measures. The DOJ emphasized its commitment to incentivizing good behavior.
PAAS Tips:
DMEPOS Updates: Annual Reaccreditation Surveys, New Site Visit Service Contractors
PAAS National® wants to alert members to a few recent changes that may impact pharmacies who are dispensing DMEPOS supplies to Medicare 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:
Onsite Audit Preparation – Partial Dispensing Policy
Partially dispensing prescriptions is a common, and practical, approach used in pharmacy practice to ensure patients receive timely access to medications when the full prescribed quantity is not immediately available. Rather than delaying therapy, a pharmacy may dispense a portion of the medication and provide the remaining balance at a later time.
Partial dispensing most often occurs because of inventory shortages, wholesaler delays, or even manufacturer backorders. Regardless of the reason, the pharmacy’s primary goal is to prevent interruptions in therapy, especially for medications that are critical to a patient’s health.
As many independent pharmacies know, onsite audits are often the most stressful, and contentious, audit type. Beyond prescription documentation, auditors are known to ask for various policies and procedures, frequently requesting a partial fill/dispensing policy. Because of the circumstances [of an onsite audit], pharmacies are leery about saying the wrong thing.
With partial dispensing, …
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: