As 2022 comes to a close, we know that many pharmacies will make “bulk purchases” ahead of the new year in anticipation of price increases or to obtain wholesaler rebates. Remember that Caremark requires pharmacies to provide notice of any bulk purchases that may impact future invoice audits, in accordance with Section 8.05 of the Caremark Provider Manual.
If your pharmacy plans to make any large purchases, be sure to
- Pharmacy NCPDP
- Contact email address
- Drug name
- Total quantity purchased
- Name of wholesaler used
Pharmacies should submit notifications to the addresses provided below.
Attn: Bulk Purchase Notification, MC 020
9501 E. Shea Blvd. Scottsdale, AZ 85260
PAAS National® analysts have seen a few Caremark response letters that state the following, “review of the recent purchases made show they are routine in nature and would not be considered a bulk purchase”. It is unclear what criteria are used to make this determination; however, PAAS believes it is in your best interest to submit such notifications when the purchases are larger than what is “normal” for your pharmacy. We suggest that pharmacies retain this response from Caremark such that you could use it in the event of a future audit to demand that these purchases are included.
Lastly, some pharmacies have been confused by automatic email replies from Caremark with subject of Automatic Reply: Pharmacy Audit and the body of the email stating that the email address is a general mailbox for potential pharmacy audit issues and provides further instructions on how to submit “internal requests” and “external requests”. PAAS has confirmed that these are simply automatically generated replies and that pharmacies will receive a response specific to the bulk purchase notification within a few days.
- See previous PAAS communications for additional background information
- June 15, 2022 on-demand webinar Caremark’s Bulk Purchasing Requirements
- June 2022 Newsline article Understanding Caremark’s Restrictions on Bulk Purchases
- 2022 CVS Caremark Provider Manual Supplement for 2023 - January 1, 2023
- Essential Elements of Corrective Action Plans - December 31, 2022
- Medicare Extends Part B Coverage for Kidney Transplant Drugs - December 29, 2022