It is that glorious time of year again! Time for staff to be occupied not only with the daily activities of billing and filling medications, but also occupied with cough/cold/flu season, vaccine administration, answering Medicare Part D open enrollment questions, and holiday closures. Now is the time to ensure staff complete their annual Fraud, Waste & Abuse and HIPAA Compliance, Cultural Competency, and USP 800 Compliance training since the December 31st deadline will be here before we know it!
FWA/HIPAA Compliance Training: Employees who are involved with filling, billing, dispensing or delivery of Medicare and/or Medicaid prescriptions are required to be trained within 30 days of hire (per PBM requirements) and at least annually thereafter. Per CMS Chapter 9.50.3, training and education for employees does include the CEO and senior administrators or managers. Relief pharmacists, students, interns, job shadows, and delivery drivers also need training. The training must cover FWA and General Compliance topics and must include details outlining your pharmacy’s specific policies and procedures of how you prevent, detect, and correct FWA.
Current PAAS National® FWA/HIPAA Compliance Program members can meet annual training requirements through the PAAS Member Portal. A few important things to note:
- All employees must complete the 2024 FWA Modules 1-4 and review/sign the Employee Compliance Training Handbook and Code of Conduct to meet training requirements.
- If a staff member misses the December 31st deadline, 2024 training cannot be retrospectively completed.
- Account administrators that have employees with outstanding quizzes or signatures will receive two more email reminders from PAAS before the end of the year.
Cultural Competency Training: As of April 2021, NCPDP required pharmacies to indicate if they train their staff on cultural competency and maintain evidence of such training, when going through the pharmacy’s annual NCPDP profile credentialing. Since adding this question, PBMs have decreased the number of direct attestations required of community pharmacies. However, indicating ‘no’ in NCPDP is not without potential repercussions as PBMs may exclude you from provider listings of culturally competent care, as this was required for Medicaid managed care plan directories. Additionally, there are federal requirements that have been in place for many decades. Read more on Does My Pharmacy Really Need Cultural Competency Training?
USP 800 Compliance Training: USP 800 is not just for compounding pharmacies, this occupational exposure extends to everyone working in the pharmacy, from the pharmacists and pharmacy technicians who handle hazardous drug (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 greatly reduce risk. Per OSHA, the safe handling of hazardous drugs in accordance with USP 800 is now 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 your employees, patients in your pharmacy, and the environment. It can also help reduce employer liability from frivolous lawsuits through employee training, competency documentation and employee acknowledgements.
If you are unsure of all the necessary requirements, contact PAAS at (608) 873-1342 today for more information.
Why the Unit of Measure Matters in Audits: A Small Factor with Big Consequences
A unit of measure (UOM) provides standards to define physical quantities. Without a UOM, a number is left open for interpretation, and while common sense often prevails for pharmacies, third-party auditors look for explicit instruction. With an ambiguous, or absent, UOM (primarily an issue with electronic prescriptions), an auditor may flag the claim as discrepant and attempt to recoup the claim.
PAAS National® regularly sees auditors claiming …
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:
2024 Self-Audit Series #10: Nasal and Oral Inhaler Prescriptions
Nasal and oral inhaler prescriptions are frequently targeted for audit by all PBMs. Not only have these medications increased in cost but are frequently billed incorrectly, creating the potential for easy recoupments.
Pharmacy staff should be trained to accurately bill days’ supply for all inhalers. PAAS National® has created tools for our members to aid in the data entry process. Visit the Member Portal to access these resources – Nasal Inhalers Chart and Oral Inhalers Chart – and share with staff for easy reference when billing inhalers.
The following are examples of inhaler prescriptions at a higher risk of being flagged as refill too soon due to atypical dosing (when plan limits days’ supply to 30):
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:
PAAS Audit Assistance members can search the Newsline archive for keyword “2024 self-audit” to read previous articles in this series. If you have any questions on accessing the Member Portal, or need help adding employees so they have access, please contact us.
NADAC Survey: What is It and Do I Need to Respond?
Pharmacies that receive a National Average Drug Acquisition Cost (NADAC) Survey frequently contact PAAS National® for information and guidance. While this survey remains voluntary, pharmacies may want to take a minute to understand what the survey is about.
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:
New Tool on PAAS Portal – Exceeding Days’ Supply Plan Limits for Unbreakable Packages
PAAS National® is continuously updating and creating new tools to help our members address common audit recoupment issues. Pharmacies frequently face recoupments due to overbilling multiple unbreakable packages or refilling claims too soon when billing for a single unbreakable package that exceeded the plan’s days’ supply limit.
The new tool, Exceeding Days’ Supply Plan Limits for Unbreakable Packages, provides a flow chart to follow based upon whether you are billing single or multiple unbreakable packages and receive a days’ supply plan limit rejection. Here is an example of each scenario:
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:
Ask a PAAS Expert
While PAAS National® prides itself on being audit experts, audit assistance is more than just reactive support when an audit notice arrives. PAAS works tirelessly to provide pharmacies with tools and resources to reduce their audit risk and lessen the chances of being audited. Moreover, PAAS serves as a guiding light for community pharmacies with day to day pharmacy audit questions. Get expert answers to your questions on:
As a trusted partner, we provide tailored guidance to help you prevent audits. Remember, the prescription claims you submit today are the audits of the future.
Work to audit-proof your pharmacy today, do it right, and avoid future recoupments. Contact us to submit a question or complete the form on the Member Portal.
Ensure Your Team Is Prepared for PBM Audits
In an interview with Pharmacy Times at the National Association of Community Pharmacists 2024 Convention & Expo, Trent Thiede, PharmD, president of Pharmacy Audit Assistance Service (PAAS) International, discussed how pharmacy teams can remain prepared for audits from pharmacy benefit managers (PBMs).
Q: What are the common types of PBM audits that pharmacies face, and what specific documentation or records are typically requested? How do you stay informed about evolving audit requirements and best practices?
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Click here to read more at PharmacyTimes.com
Best Practices for Proactively Preventing PBM Audit Issues | NCPA 2024
Pharmacy Benefit Managers (PBMs) routinely conduct audits on independent pharmacies with the stated goal of preventing fraud, waste, and abuse in medication dispensing. However, PBM audits often lack clear metrics and can include certain requirements without an explicit reason why. As these audits increase—in 2023 they shot up by as much as 29%1—many pharmacists who have failed them cite it as the primary reason why they can’t stay in business.2
Click here to continue to read the complete article at DrugTopics.com
Billing Coupons for Medicare Part D Patients – When Is It Okay?
The Office of Inspector General (OIG) has made it clear that using manufacturer coupon cards with federally funded programs is prohibited by Anti-Kickback Statutes [42 U.S.C. 1320a-7b]. However, pharmacies should be aware of organizations, like …
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:
Representative NDC on Electronic Prescriptions Do Not Infer Specificity
When electronic prescriptions were first introduced, they were supposed to be more convenient for patients and cause less errors at the pharmacy (due to the legible nature of the information being sent from the prescriber). In practice, we know this has not always been the case. The directions may be confusing, the quantity not specified, and even the product selection could be left to interpretation.
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 Clock is Ticking: Complete Your Annual Training!
It is that glorious time of year again! Time for staff to be occupied not only with the daily activities of billing and filling medications, but also occupied with cough/cold/flu season, vaccine administration, answering Medicare Part D open enrollment questions, and holiday closures. Now is the time to ensure staff complete their annual Fraud, Waste & Abuse and HIPAA Compliance, Cultural Competency, and USP 800 Compliance training since the December 31st deadline will be here before we know it!
FWA/HIPAA Compliance Training: Employees who are involved with filling, billing, dispensing or delivery of Medicare and/or Medicaid prescriptions are required to be trained within 30 days of hire (per PBM requirements) and at least annually thereafter. Per CMS Chapter 9.50.3, training and education for employees does include the CEO and senior administrators or managers. Relief pharmacists, students, interns, job shadows, and delivery drivers also need training. The training must cover FWA and General Compliance topics and must include details outlining your pharmacy’s specific policies and procedures of how you prevent, detect, and correct FWA.
Current PAAS National® FWA/HIPAA Compliance Program members can meet annual training requirements through the PAAS Member Portal. A few important things to note:
Cultural Competency Training: As of April 2021, NCPDP required pharmacies to indicate if they train their staff on cultural competency and maintain evidence of such training, when going through the pharmacy’s annual NCPDP profile credentialing. Since adding this question, PBMs have decreased the number of direct attestations required of community pharmacies. However, indicating ‘no’ in NCPDP is not without potential repercussions as PBMs may exclude you from provider listings of culturally competent care, as this was required for Medicaid managed care plan directories. Additionally, there are federal requirements that have been in place for many decades. Read more on Does My Pharmacy Really Need Cultural Competency Training?
USP 800 Compliance Training: USP 800 is not just for compounding pharmacies, this occupational exposure extends to everyone working in the pharmacy, from the pharmacists and pharmacy technicians who handle hazardous drug (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 greatly reduce risk. Per OSHA, the safe handling of hazardous drugs in accordance with USP 800 is now 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 your employees, patients in your pharmacy, and the environment. It can also help reduce employer liability from frivolous lawsuits through employee training, competency documentation and employee acknowledgements.
If you are unsure of all the necessary requirements, contact PAAS at (608) 873-1342 today for more information.