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.
Evaluating the Days’ Supply of Migraine Medications
PAAS National® analysts continue to see as needed migraine medications undergo increased scrutiny during audits, and unfortunately, the auditors are (too often) successful in their recoupment efforts.
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:
Are You Getting the Most from Your PAAS National® Membership?
While PAAS National® may be known for our best-in-class, hands-on audit assistance, we also offer insightful and educational information and resources that you may be missing out on! Below is a list of resources found in the Audit Assistance section of the Member Portal that could help ensure you and your pharmacy staff stay educated and informed when it comes to audits.
Updates will occur to these resources whenever necessary, like adding a drug to our Dispense in Original Container Chart or adjusting information on our days’ supply charts. If these resources are printed for easy viewing access, be sure to occasionally check on the website for the “Last Updated” section above these resources to ensure you have the most up-to-date version printed.
PAAS Tips:
DOJ Expands Health Care Fraud Units: What It Means for Pharmacies
The U.S. Department of Justice (DOJ) has announced an expansion of its Health Care Fraud Unit. The New England Strike Force—formerly responsible for Maine, New Hampshire, and Vermont—now includes Massachusetts. With this change, there are nine Health Care Fraud Strike Force locations nationwide, covering many of the country’s largest metropolitan areas.
The Health Care Fraud Unit is a specialized division within the DOJ that investigates and prosecutes fraud involving federal health care programs such as Medicare, Medicaid, and TRICARE. Its core mission is to protect taxpayer dollars, ensure patient safety, and uphold the integrity of the health care system.
For pharmacies, this expansion underscores the government’s increasing focus on detecting and preventing fraud related to billing, controlled substances, and prescription claims. The unit collaborates closely with the Office of Inspector General (OIG), Drug Enforcement Administration (DEA), and Federal Bureau of Investigation (FBI) to identify and prosecute fraudulent activities—including schemes involving unnecessary prescriptions, false claims, and diversion of controlled substances.
The DOJ relies heavily on data analytics and advanced algorithms to detect emerging fraud patterns and pinpoint high-risk behaviors. This means pharmacy billing and dispensing data may be analyzed for irregular trends or red flags, particularly in cases involving opioids or other controlled medications.
Pharmacies can reduce their risk by maintaining robust compliance programs, conducting regular internal audits, and ensuring accurate documentation of all prescriptions and reimbursements. As the Health Care Fraud Unit’s reach expands, proactive compliance and vigilance will remain essential for all pharmacy professionals.
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:
Why Copays for Pharmacy Staff Should NOT Be Waived
Successful pharmacies recognize the immense value of team members who are dedicated, diligent, knowledgeable, and reliable. With the financial squeeze in community pharmacies, payroll can be a tough spot to spend extra money. Having the employee fill prescriptions at the pharmacy they work in, and not having them pay the resulting copay, can be a nice gesture, but there may be consequences.
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:
Pitfalls with the Most Common DAW Codes Billed
PBMs and audit companies pay close attention to how pharmacies bill claims, including which DAW code was used. This seemingly innocent billing element can cause significant audit issues if not used properly. Any DAW (other than 0) should have supporting documentation for why it was appropriate to use. PBMs will continue to pay close attention to this billing element due to pharmacy reimbursement and/or patient copay differences potentially being influenced by the billed DAW code. Below are the more common DAW codes we see billed and some considerations to take when processing a claim.
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:
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.