This month at PAAS National® we celebrate one year of the launch of the PAAS Vault. This product was developed to help pharmacies access their important documents easily, and safely store them securely in one central location. Available to you at your fingertips 24/7 to assist in reducing the stress of having to search for each document.
From our members:
“We are a small ma/pa shop. We renewed the PAAS Vault as we can see how easy it is for renewals during that time of the year.”
“Our pharmacy was previously in the need of a better way to track the expiration of our licenses, certificates, insurance, contracts, etc. The PAAS vault provided us the ability to have one web-based platform that was able to house the necessary documents needed to maintain compliance as well as track upcoming expiration dates. The trial has been very valuable. It has allowed me to play around with the features of this new service and see first-hand the benefit it provides to our compliance program. The part I like best is that I can attach physical documents as well as enter expiration dates where I can quickly see on the dashboard page upcoming expirations that need to be addressed. I would like to be able to use this service in an expanded way in the future. For example being able to store payer audit documents/findings, board of pharmacy inspection reports, and payer contracts for easy retrieval.”
“Going to be really useful. I forgot to renew one and that shouldn’t happen now with the [PAAS] Vault program. About 2/3 of the way done entering info. I really like the reminders, so nothing slips through the cracks. Great safety net.”
“We like the [PAAS] Vault and having everything at your finger tips and easily accessible. It is an easy application, easy to upload files, reminders auto send out and will save alot of last minute scrambling and headaches.”
“Keep track of licenses, as we currently just have reminders set-up on our calendar. The trial has been valuable to us, which is an add-on for FWAC members at $99/year after the trial period.”
PAAS National® FWA/HIPAA Compliance members that have added the PAAS Vault can upload, retrieve, and print their documents fast and easy with just a few clicks. With the custom alerts and reminders, the PAAS Vault makes it is easy to know when these documents need renewing as well.
Let us know if you have any questions or concerns on how to use the PAAS Vault. Compliance Officers and Administrators can also refer to the PAAS Vault User Guide found on the Help page of the PAAS Portal.
Not a PAAS FWA/HIPAA compliance member? Contact us today at (608) 873-1342 or info@paasnational.com and save $120 by combining services with PAAS Audit Assistance.
Celebrating 1 Year of License Tracking with the PAAS Vault
This month at PAAS National® we celebrate one year of the launch of the PAAS Vault. This product was developed to help pharmacies access their important documents easily, and safely store them securely in one central location. Available to you at your fingertips 24/7 to assist in reducing the stress of having to search for each document.
From our members:
“We are a small ma/pa shop. We renewed the PAAS Vault as we can see how easy it is for renewals during that time of the year.”
“Our pharmacy was previously in the need of a better way to track the expiration of our licenses, certificates, insurance, contracts, etc. The PAAS vault provided us the ability to have one web-based platform that was able to house the necessary documents needed to maintain compliance as well as track upcoming expiration dates. The trial has been very valuable. It has allowed me to play around with the features of this new service and see first-hand the benefit it provides to our compliance program. The part I like best is that I can attach physical documents as well as enter expiration dates where I can quickly see on the dashboard page upcoming expirations that need to be addressed. I would like to be able to use this service in an expanded way in the future. For example being able to store payer audit documents/findings, board of pharmacy inspection reports, and payer contracts for easy retrieval.”
“Going to be really useful. I forgot to renew one and that shouldn’t happen now with the [PAAS] Vault program. About 2/3 of the way done entering info. I really like the reminders, so nothing slips through the cracks. Great safety net.”
“We like the [PAAS] Vault and having everything at your finger tips and easily accessible. It is an easy application, easy to upload files, reminders auto send out and will save alot of last minute scrambling and headaches.”
“Keep track of licenses, as we currently just have reminders set-up on our calendar. The trial has been valuable to us, which is an add-on for FWAC members at $99/year after the trial period.”
PAAS National® FWA/HIPAA Compliance members that have added the PAAS Vault can upload, retrieve, and print their documents fast and easy with just a few clicks. With the custom alerts and reminders, the PAAS Vault makes it is easy to know when these documents need renewing as well.
Let us know if you have any questions or concerns on how to use the PAAS Vault. Compliance Officers and Administrators can also refer to the PAAS Vault User Guide found on the Help page of the PAAS Portal.
Not a PAAS FWA/HIPAA compliance member? Contact us today at (608) 873-1342 or info@paasnational.com and save $120 by combining services with PAAS Audit Assistance.
Webinar: Thriving Against PBM Audits – Audit Trends and PBM Tactics
On June 23, 2021 PAAS National® hosted Thriving Against PBM Audits – Audit Trends and PBM Tactics webinar. PAAS Audit Assistance members have access to the recorded webinar, in addition to many other tools and resources on the PAAS Member Portal.
This webinar reviews:
COVID-19 Vaccine Billing Guidance (April Update)
PAAS National® has seen a few COVID-19 vaccine audits since pharmacies began billing and administering within the last few months. This article contains some reminders and updates from our January 2021 Newsline COVID-19 Vaccine Billing Guidance. As a general rule, vaccine claims are lower risk for PBM audit; however, audits are always possible, and you should be prepared with good documentation. PAAS highly recommends creating a placeholder “prescription” with all required elements for your records – many pharmacies already do this when billing for other vaccines under protocol. Additionally, it will be necessary to document the administration through a vaccine administration record as well as provide the patient with an Emergency Use Authorization (EUA) fact sheet (in place of a vaccine information sheet). Be sure to submit the correct quantity, days’ supply, SCC code and CPT code depending on which vaccine you are administering. Please see the chart below for a reference.
The coverage for COVID-19 vaccine may be under the pharmacy benefit (via NCPDP standard) or the medical benefit (via CPT codes). Here is a summary of billing information known to PAAS:
Supply
(2) Moderna vaccine has a package size of 5 mL and will deliver 10 doses of 0.5 mL
(3) Janssen vaccine has a package size of 2.5 mL and will deliver 5 doses of 0.5 mL
*NCPDP also recommends that pharmacy claims will need to submit the following for ZERO-COST vaccines:
PAAS Tips:
COVID-19 Vaccine Billing Guidance
The light at the end of the tunnel is approaching as Operation Warp Speed delivered COVID-19 vaccines to healthcare workers and LTC residents in December 2020. There will certainly be bumps in the road, supply chain delays and allocations, which means that most patients will not be able to receive COVID-19 vaccines until mid- to late 2021.
The federal government has pre-paid for millions of vaccine doses and will be distributing them to health care providers at no cost, which means that when government-supplied vaccine becomes available at community pharmacies, you will not have to pay to acquire it. For vaccine doses supplied by the federal government, pharmacies may NOT charge patients for the vaccine itself, but may bill payers for the administration. The federal government has mandated coverage under Medicare Part B, Medicaid and Commercial insurance with no out-of-pocket costs to patients. The CARES Act also provides for reimbursement for uninsured patients through the Health Resources & Services Administration (HRSA).
The coverage for COVID-19 vaccine may be under the pharmacy benefit (via NCPDP standard) or the medical benefit (via CPT codes). Here is a summary of billing information known to PAAS National® as of December 23, 2020.
NCPDP also recommends that pharmacy claims will need to submit the following for ZERO-COST vaccines:
*New guidance sent 3/15/2021 and updated article published 4/2/2021, available to members in the PAAS Portal*
FWA and HIPAA Compliance with Job Shadows and Interns
Students performing a job shadow or internship in the pharmacy need proper FWA/HIPAA training and preparation to be behind the pharmacy counter or you are inviting headaches into your operations (and potential legal complications).
Pharmacy students completing their internship typically spend more time in the pharmacy than someone job shadowing. Interns assisting with daily operations such as billing, filling, counseling, and other professional services, must also complete FWA training. Though their time with your pharmacy may be temporary, these students have access to many of the same pharmacy operations as regular employees. The potential to oversee or partake in wasteful practices, diversion, or other fraudulent activities exists and FWA training must be completed. PAAS National® also recommends completing exclusion checks for interns against both the Office of Inspector General (OIG) and General Services Administration (GSA) lists.
PAAS FWA/HIPAA Compliance members can easily add students to your employee list in the PAAS Member Portal to give them access to the FWA/HIPAA online training modules and automatically receive daily OIG and GSA exclusion checks when the student’s profile is created.
PAAS Tips:
Contact PAAS National® at (608) 873-1342 or info@paasnational.com for assistance regarding student access to the portal or to become an FWA/HIPAA Compliance member.
Pitfalls of Transferred Prescriptions
Transferred prescriptions are at high risk for audit recoupments. Every element required by state regulations is one additional pitfall that PBMs utilize to try and recoup on claims. These prescriptions are easily identified due to their origin code. The NCPDP Telecommunication Version D section 3.1.4 explains that an origin code of 5 is utilized for any pharmacy created prescription, which includes when pharmacists have authority to prescribe, when dispensing off a protocol and for prescriptions transferred in.
PAAS National® analysts frequently see audit results with recoupments for:
PAAS Tips:
Updated Dispense in Original Container Chart
Medications that are required to be dispensed in their original container continue to appear in audits. Billing for a quantity that is not divisible by the full bottle size is a red flag to the PBM and, unfortunately, easily recoupable. Many of these products are sensitive to light/moisture or have only been studied under storage in their original container; thus, removing them from the original package may cause stability and potency issues. Product labeling can be obtained from the FDA’s DailyMed website, which was referenced by PAAS National® to update the Dispense in Original Container chart under the Tools & Aids section of the PAAS member portal.
For example, PAAS analysts have seen an increase in
Additionally, pharmacies dispensing to nursing homes or providing medication packaging to patients in the retail pharmacy setting must also follow the FDA guidelines to dispense in the original container.
PAAS Tips:
Fraud, Waste, & Abuse and HIPAA Compliance Updates for 2021
PAAS National® continuously keeps close tabs on legislative and regulatory changes that may impact our members’ Fraud, Waste & Abuse and HIPAA Compliance Program. Monitoring enforcement from the Department of Justice and the Office for Civil Rights (OCR) also allows us to be aware of interpretative standards as well.
Furthermore, Pharmacy Benefit Managers (PBMs) are continuously adding and changing requirements to their credentialing process. Pharmacies need to be certain they are ready for these changes. The PAAS National® FWA/HIPAA Compliance Program has implemented changes to ensure pharmacies with our program will continue to have robust policies in place.
Does your pharmacy have a policy for Timely Submission of Claims? PAAS has increasingly become aware of this credentialing requirement. Having written policies in place will assist you with credentialing responses. PAAS FWA/HIPAA compliance members can now find this in Section 4.1.8 of their Policy and Procedure Manual.
It is also important for pharmacies to be aware of OCR’s stepped-up enforcement for Pharmacies who are not providing timely access to patient records – fines for violations have exceeded $200,000. PAAS FWA/HIPAA compliance members should review Section 10.5.1.1 of their Policy and Procedure Manual and review our January 2020 Newsline article First Two Settlements for HIPAA Right of Access Initiative by OCR.
PAAS FWA/HIPAA compliance members can login to the member portal to view the full memo of 2021 FWAC and HIPAA Updates.
With our 24/7 web-based Portal, extensive customization, and ease of use, it’s easy to see why most PAAS members use our FWA/HIPAA compliance program.
Are You Documenting DUR and Submission Clarification Codes?
PAAS National® is continuing to see Express Scripts (ESI) and Tricare flag claims for audit where clinical drug utilization review (DUR) or submission clarification codes (SCC), were submitted. Prime Therapeutics, now processed by ESI, has now joined in. Recoupments are happening due to “No DUR documentation” or “No SCC documentation.” Pharmacies that fail to show documentation of the support codes used on the prescription are facing recoupment.
Dispensing pharmacists must use professional judgement when receiving a point-of-sale reject. If choosing to dispense a medication using an override code, it is imperative that supporting documentation be placed on the prescription to support its utilization. This documentation should contain detailed information with dates, names, titles, and discussions that took place if patients, or prescribers, were consulted. Lack of this documentation can lead to recoupment.
Most common SCCs subject to audit (as defined by NCPDP) are:
Please click here to view all 37 NCPDP Submission Clarification Codes and their corresponding definitions. There are additional codes found in the link that pertain to LTC billing, compounds and 340B. Drug utilization review codes can be found as follows: Reason for Service Code, Professional Service Code (NCPDP 440-E5) and Result of Service Code.
PAAS Tips:
340B Contract Pharmacy Claims Identification and Submission Requirements
Major PBM Updates Network Provider Manual
For 2021, a major PBM updated their provider manual regarding their position on the 340B drug discount program. Previously stating the PBM encourages Network Providers to identify 340B claims, in 2021 that language was updated to state Providers must identify the claims. This update included a March 1, 2021 effective date for processing what is called N1 (information reporting) transactions. Read the full release.