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.
Facing Potential Disciplinary Action? PBMs Require Notification!
It can be a very stressful time for a pharmacy when they, or an employee, are being investigated by a regulatory body (e.g., Board of Pharmacy, Office of Inspector General (OIG) or Drug Enforcement Agency). It will likely not be the first thing on your mind to notify contracted PBMs. Consider
It’s important to note that OptumRx is requiring notification even if no disciplinary action was taken against the pharmacy or the employee. Every PBM may have different requirements, but the major PBMs require some sort of notification. Be sure to review a copy of the Provider Manual if you are unaware of the regulations regarding this issue.
These situations often arise after re-credentialing as PBMs are reviewing the credentials of pharmacy employees. PAAS National® has successfully assisted pharmacies facing Network Termination due to a failure to notify. Notify PAAS right away if you’ve received a Letter of Warning (Contract Violation) leading to a breach of the Provider Agreement.
AmerisourceBergen ThoughtSpot 2021: Navigating Pharmacy Audits Amidst a Pandemic
Pharmacy audits continue to morph as Pharmacy Benefit Managers (PBMs) develop new methods to recoup prescription claims. Understanding the many facets of the audit process, including triggers, trends, and prevention strategies will enable your pharmacy to be more successful in an audit situation.
On Tuesday, August 3, 2021 from 2:00-3:30 p.m. EST, Trent Thiede, President at PAAS National® and Tracie Acosta, Manager of Provider Network Quality Compliance from Elevate Provider Network will be virtually presenting Navigating Pharmacy Audits Amidst a Pandemic in an online CE webinar at the AmerisourceBergen ThoughtSpot 2021.
Time will also be spent discussing the unique challenges immunizations, 340B claims, compounds, and LTC prescriptions present on audits. Takeaways from this session include:
For catching this webinar session and more, visit the ThoughtSpot 2021 website: https://www.wearegnp.com/thoughtspot2021
Announcing the new PAASNational.com
After many months of hard work and dedication from our team, we are pleased to announce that on June 22, 2021 we launched the new PAAS National® website paasnational.com.
The primary goal of the redesign was to create a valuable, mobile friendly resource for visitors to access information on PAAS Audit Assistance and Fraud, Waste & Abuse/HIPAA Compliance services and keep up-to-date on news and events. Visitors can also easily view the different membership offerings at https://paasnational.com/buy-now/.
PAAS members have access to the PAAS member portal by clicking the “Member Login” button in the upper right hand corner of the screen to unlock the resources available with their specific membership type, which may include: audit assistance, proactive tips, on-site credentialing tools, days’ supply charts, COVID-19 resources, recorded webinars, guidance on filling and billing prescriptions, policy and procedure manual, risk analysis, FWA/HIPAA training, OIG & GSA exclusion list checking and more.
The website also includes member testimonials and audit assistance results. We love hearing from our members at info@paasnational.com and we have made it easier to refer a friend: https://paasnational.com/refer-a-friend/
We hope you enjoy the new website! For any suggestions, questions or comments please contact us: https://paasnational.com/contact/
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: