Caremark issued a Pharmacy Update memo on March 8, 2023, stating that they would resume signature log requirements for audits effective May 12, 2023. This coincides with Health and Human Services (HHS) announcement that the formal COVID-19 public health emergency (PHE) will expire on May 11, 2023.
PAAS National® expects other PBMs to follow suit in short order and we recommend that pharmacies begin to transition staff and patients back to pre-pandemic workflow, if you have not done so already. Remember that upon audit, PBMs want to see at least three elements on signature logs – the prescription number, the date dispensed and the signature of patient or representative (some PBMs, like Humana, may also want to see the fill date or fill “number”). For prescriptions that are mailed, make sure that you maintain tracking/delivery confirmation as well.
- As Caremark is giving pharmacies 60 days of advanced notice of this policy change, we do not expect that they will be lenient in future audits, or provide any consideration for pharmacies that “did not know”
- PAAS Audit Assistance members can check out the following Newsline articles for additional tips:
- March 2023, PHE for COVID-19 Ending May 11, 2023: Pharmacy and Audit Ramifications for more details on the PHE ending May 11, 2023.
- February 2023, Are Yor Delivery/Signature Logs PBM Compliant for 2023?
- Specialty Pharmacy Paying the Price: $20 Million Settlement for Kickbacks and Copay Waivers - November 9, 2023
- Advances in Respiratory Syncytial Virus (RSV) Prevention - November 1, 2023
- OTC COVID-19 Test Prescribing Authority - October 20, 2023