Telemedicine Audits: Are Your Prescriptions Legitimate?

During the Public Health Emergency, telemedicine has become a convenient, and much more common, way for patients to communicate with their healthcare team; especially when patients and healthcare facilities are wary of in-person appointments. Unfortunately, telemedicine also continues to be an easy target for bad actors, with pharmacies being caught in the middle.

In August, Prime Therapeutics reported that telemedicine schemes contributed to a 60% increase in reported false claims during 2020. In one investigation, Prime pointed to a pharmacy’s use of “high-risk, low-value” products that allowed a pharmacy to transmit $300K in their first month of doing such business. This pharmacy was terminated from the network, reported to the Board of Pharmacy and Department of Insurance, and had funds recouped.

Another example is the DEA’s announced criminal charges in a September 17, 2021 press release against 138 defendants across 31 federal districts for alleged participation in fraud schemes including $1.1 billion in telemedicine fraud. Court documents noted that telemedicine executives paid doctors and nurse practitioners to order unnecessary equipment, tests, and pain medications either without having any patient interaction or after a simple phone call with the patient whom they had never met or saw for a medical purpose. Fraudulent claims were then submitted to Medicare and other government insurers, including for telehealth consultations that did not happen in the way they were represented to the insurers. Profits made off these schemes were found to have been spent on luxury items like yachts, vehicles, and real estate.

How does a pharmacy avoid the bad actors in telemedicine and still help their legitimate patients? Background research may be necessary to understand whether prescriptions were generated from a real patient-prescriber relationship and are medically necessary. The following items should be considered before dispensing any telemedicine prescription.

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  • Does the prescription conform to all state and federal laws?
  • Is the prescription a template form?
    • Is every prescription for the same drug, quantity, directions, and refills regardless of a patient’s individual treatment needs?
    • Are the drugs listed all high-cost products and/or have clinically appropriate lower cost alternatives?
    • Does the prescription include substitution cascades or overly broad substitution allowances without consultation with the prescriber needed?
    • Forms with pharmacy branding can lead to problems with patient steering/patient choice laws.
  • How many items are prescribed?
  • Why did the prescription come to your pharmacy?
    • Is this a regular patient of yours?
    • Was the patient referred to your pharmacy by the prescriber?
    • Is there an intermediary routing the prescription to you like a marketing company or a pharmacy that never fills prescriptions but only transfers them out?
  • How did the prescription come to your pharmacy?
    • Facsimile? E-prescription?
    • Transfer?
    • Email/Drop Box are red flags


  • Is this a regular patient?
    • If not, where is their regular pharmacy?
    • Why did their prescription come to you?
  • Are you filling all the patient’s medications or just the telemedicine ones?
  • Did the patient request the medication be filled?
    • Some PBMs are requiring proof that the patient requested a medication be filled in the form of a documented conversation with the patient by the pharmacy.
  • Why is the patient utilizing telemedicine?
    • Is the patient in a rural area with little access to healthcare?
    • Is the patient being treated by a specialist not available locally?
    • Online surveys or telemarketing calls are a red flag.
  • Is there a legitimate patient/prescriber relationship?
    • Does the patient regularly see this prescriber?
    • Does the patient live in the same area where the prescriber’s office is located?
    • Would you be able to obtain medical records to validate this relationship?


  • Is this the patient’s regular prescriber or healthcare system?
  • Is there a legitimate patient/prescriber relationship (see above) and could you prove it if asked?
  • Is the prescriber licensed in the state where the patient resides?
  • Is the medication prescribed within the prescriber’s scope of practice?
  • How were healthcare services provided?
    • Video chat?
    • Simple telephone call?
  • Who paid the prescriber for the telemedicine encounter/visit?
    • Patient or health plan?
    • If the pharmacy or a marketing company paid for the visit, this could be seen as an illegal kickback.

Further exemplified by the US Department of Health and Human Services-Office of Inspector General report issued October 18, 2021, 84% of Medicare beneficiaries who received telehealth services had an established relationship with the provider prior to the telehealth visit.

Finally, if your pharmacy does fill prescriptions for telemedicine, and you determine the prescriptions are legitimate, you also need to follow any state Boards of Pharmacy pertaining to mailing or delivery of prescriptions. This includes confirming if your pharmacy needs to be licensed in a state other than your own that you may be shipping medications to and within PBM contractual limits that may prohibit mailing or delivery outside a certain mile radius of your pharmacy.

LIVE WEBINAR NOV. 18: PBM FWA Trends and COVID-19 Vaccine Audit Risks

Join President of PAAS National®, Trenton Thiede, PharmD, MBA for a LIVE webinar “PBM FWA Trends and COVID-19 Vaccine Audit Risks” on November 18, 2021 from 2-2:30pm CT as he discusses:

  • Who We Are and How We Help
  • PBM Fraud, Waste and Abuse (FWA) Trends
  • COVID-19 Vaccine Audit Risks
    • Documentation Requirements
    • Additional Doses for Immunocompromised
    • Booster Doses for qualified patients
    • Medicare at-home patients
  • Pandemic related PBM waivers/concessions

We will allow for some Q&A at the end of the webinar.


PAAS Audit Assistance members will have access to a recording on the PAAS Member Portal if they are unable to attend the live event.

PREP Act Ninth Amendment – Overview and Audit Guidance for Subcutaneous REGEN-COV

The ninth amendment to the Public Readiness and Emergency Preparedness (PREP) Act was published in the Federal Register on September 14th, 2021, which granted pharmacists the authority to order and administer COVID-19 therapeutics and qualified pharmacy technicians and pharmacy interns to administer COVID-19 therapeutics under the supervision of a pharmacist. The PREP Act only covers COVID-19 therapeutics by subcutaneous, intramuscular, or oral administration—therefore, IV infusion would not be covered under this amendment.

At the time of publishing, only one COVID-19 therapeutic is available for administration under the ninth amendment of the PREP Act. The co-formulated solution, REGEN-COVTM, qualifies because it has FDA emergency use authorization (EUA) for administration via subcutaneous injection in addition to IV infusion. REGEN-COVTM contains two monoclonal antibodies (mAbs), casirivimab and imdevimab, and is authorized for the treatment of certain patients with COVID-19 and for post-exposure prophylaxis in eligible patients.1,2

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proved Use1,2 Coverage Criteria1,2,3,4 Dosage1,2,5
Treatment of COVID-19

ICD-10 Code



  • Mild-to-moderate COVID-19 symptoms within 10 days of onset without requiring hospitalization or oxygen supplementation due to COVID-19 (or requiring more oxygen than baseline)
  • Adult or pediatric patient (≥ 12 years old and ≥ 40 kg)
  • Positive results of direct SARS-CoV-2 viral testing
  • High risk for progressing to severe COVID-19, including hospitalization or death
600 mg casirivimab + 600 mg imdevimab

IV infusion is preferred, but subcutaneous injection is authorized when infusion is not feasible or would delay treatment.

Post-Exposure Prophylaxis

ICD-10 Code



  • Adult or pediatric patient (≥ 12 years old and

≥ 40 kg)

  • High risk for progressing to severe COVID-19, including hospitalization or death
  • Not fully vaccinated -OR- not expected to fully respond to vaccine (i.e. immunocompromised)
  • Had close contact with an infected individual per CDC criteria -OR- is at high risk for exposure to an infected individual due to infection in other individuals in same institutional setting

600 mg casirivimab + 600 mg imdevimab


Patients with repeat exposure expected to last more than one month may receive additional doses once every 4 weeks for the duration of the ongoing risk

300 mg of casirivimab + 300 mg of imdevimab

1FDA EUA for REGEN-COVTM, September 9, 2021. (Accessed September 13, 2021).

2FDA Fact Sheet for Health Care Providers EUA of REGEN-COVTM (casirivimab and imdevimab). September 2021.  (Accessed October 12, 2021).

3NIH Anti-SARS-CoV-2 Monoclonal Antibodies Treatment Guidelines. August 4, 2021. (Accessed September 27, 2021).

4Close Contact per CDC criteria: (Accessed September 29, 2021).

5REGEN-COVTM: Subcutaneous Injection Instructions for Healthcare Providers July 28, 2021. (Accessed October 12, 2021).

High-Risk Conditions1,2,3
  • Older age (e.g., age ≥65 years old)
  • Obesity or being overweight (adult with BMI >25 kg/m2, or if age 12-17, BMI ≥85th percentile for age and gender based on CDC growth charts)
  • Pregnancy
  • Chronic kidney disease
  • Diabetes
  • Immunosuppressive disease or immunosuppressive treatment
  • Cardiovascular disease (including congenital heart disease or hypertension)
  • Chronic lung diseases (e.g., COPD, moderate-to-severe asthma, interstitial lung disease, cystic fibrosis, pulmonary hypertension)
  • Sickle cell disease
  • Neurodevelopmental disorders (e.g., cerebral palsy)
  • Conditions with medical complexity (e.g., genetic or metabolic syndromes and severe congenital anomalies)
  • Having a medical-related technological dependence (e.g., tracheostomy, gastrostomy, positive pressure ventilation [not related to COVID-19])
  • Other conditions/risk factors making the patient high risk for severe COVID-19 (e.g., race, ethnicity) – health care providers should consider the benefit-risk of treatment for each patient

*Additional conditions can be found on the CDC’s COVID-19 Underlying Conditions or People with Certain Medical Conditions webpage

1FDA Fact Sheet for Health Care Providers EUA of REGEN-COVTM (casirivimab and imdevimab). September 2021.  (Accessed October 12, 2021).

2CDC. COVID-19 Underlying Medical Conditions. May 2021. (Accessed October 12, 2021).

2CDC. COVID-19 People with Certain Medical Conditions. Aug 2021. (Accessed October 13, 2021).

When billing REGEN-COVTM, request reimbursement only for the administration fee (aka incentive amount) since the therapeutic agent is provided to the pharmacy at no cost by the federal government. To bill Medicare, the pharmacy must be enrolled as a Part B provider and utilize a medical billing intermediary. For claims billed to plans other than Part B, REGEN-COVTM may or may not be covered by either the pharmacy or medical benefit and cost-sharing is possible. Based on guidance from CMS, below are the billing codes for REGEN-COVTM (NDC 61755-0039-01; 10 mL vial).

sage of casirivimab + imdevimab Medicare Benefit
Drug HCPCS Code Administration HCPCS Code Administration Code Description Incentive Amount*
600 mg + 600 mg

(1,200 mg total)

Q0244 M0243 Outpatient initial SubQ injection and post-administration monitoring $450
600 mg + 600 mg

(1,200 mg total)

Q0244 M0244 Home or residence initial SubQ injection and post-administration monitoring in the home or residence $750
300 mg + 300 mg

(600 mg total)

Q0240 M0240 Outpatient subsequent repeat doses SubQ injection and post-administration monitoring $450
300 mg + 300 mg

(600 mg total)

Q0240 M0241 Home or residence subsequent repeat doses SubQ injection and post-administration monitoring in the home or residence $750

*This rate covers the administration fee plus the minimum required 1-hour post-injection clinical observation period

PAAS Tips: 

  • Robust documentation is extremely important – be audit-ready by having all the following for each claim:
  1. A placeholder hardcopy
  2. Confirmation of the patient’s eligibility with a signed attestation (COVID-19 treatment also requires valid test results)
  3. An administration log signed and dated by the patient, pharmacist, and staff who administered the therapeutic agent

Stark Law and Anti-Kickback Violations –Indictments Handed Down for Medically Unnecessary Claims

According to a September 17, 2021 press release from the Department of Justice (DOJ), a podiatrist was indicted for defrauding Medicare and Medicaid “by prescribing and dispensing medically unnecessary foot bath medications.” The podiatrist owned a foot clinic along with several in-house pharmacies. When the doctor wrote prescriptions, which were subsequently filled at an in-house pharmacy, he benefited financially from the “drug cocktail” prescribed – the higher the price of the cocktail, the higher the profit for the podiatrist. The article explains the “cocktails included capsules, creams, and powders that were not indicated to be dissolved in water and some of which were not water soluble.” To illustrate how expensive these “medically unnecessary” prescriptions were, over one year, Medicare paid the pharmacy over $18,000 for a single patient’s claims. The podiatrist faces up to 50 years in prison for his scheme to defraud Medicare and Medicaid.

Less than a month later, on October 4, 2021, the DOJ released another statement regarding medically unnecessary foot soaks. In this case, a federal grand jury indicted a pharmacist for allegedly utilizing a marketing company to solicit prescriptions for “foot bath” medications, paying the marketing company kickbacks by providing a percentage of the profit gained off each prescription obtained through their service, knowingly filling prescription which were medically unnecessary, and knowingly filling prescriptions where a valid patient/provider relationship was not established. The pharmacist faces one count of health care fraud and three counts of violations of the Anti-Kickback Statute [42 U.S.C. § 1320a-7b(b)]. Willingly incentivizing prescribers or patients by directly or indirectly providing remuneration is a clear violation of the Anti-Kickback Statue which could result in exclusion from all Federal health care programs, criminal penalties, and monetary penalties including up to three times the amount of the kickback.

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Both cases are good reminders of the importance of the relationship between the patient, prescriber, and pharmacy as well as the medication itself and whether it is being used for a medically acceptable indication via the appropriate route of administration.

Being aware of the prescriber/pharmacy relationship is important due to the Physician Self-Referral Law, better known as the Stark Law. If a physician or a member of the physician’s immediate family has a financial relationship with a pharmacy and the prescriber refers a patient to that pharmacy, there is a potential violation of the Stark Law. The law also prohibits billing an item as a result of the prohibited referral. Additional information, including covered items or services and exceptions can be found on or within section 1877 of the Social Security Act (42 U.S.C. § 1395nn).

The relationship between the medication prescribed, the route of administration, and the indication for use should also be considered prior to dispensing. Claims billed under federally funded plans for prescriptions utilized for non-FDA approved indications and for administration by non-FDA approved routes (e.g., topical antifungal cream dissolved in a foot bath) may be subject to recoupment. These claims may be flagged due to lack of supporting evidence for use in Part D compendia. PAAS National® analysts continue to see enforcement of this policy.

PAAS Tips:

Vaccinating Outside of Approved COVID-19 Emergency Use Authorization Has Legal Ramifications

As reported in a September 27, 2021 article by the US Attorney’s Office, the owner of a pharmacy in Juana Díaz, Puerto Rico, “knowingly and willfully” administered vaccine outside of the Emergency Use Authorization (EUA) and subsequently billed Medicaid for the claims. Twenty-four children between 7-11 years of age were vaccinated with the Pfizer-BioNTech COVID-19 vaccine.  The current EUA is solely for the age group of 12-15 years of age, with patients 16 years or older FDA-approved. Pharmacies are required to follow the requirements pertaining to COVID-19 vaccine administration set forth by the FDA, which includes any EUAs in place. Due to the violations, the owner was charged with “participating in a felony conspiracy to convert government property and to commit health care fraud”, to which they plead guilty. For the guilty plea, they voluntarily forfeited their right as a provider for all federal health care programs for five years and returned the reimbursement paid to the pharmacy by the illegitimate Medicaid claims to the United States. In addition, they face up to five years in prison, a fine of up to $250,000, and three years of supervised release.

Due to the seriousness of administering COVID-19 vaccine outside of FDA guidance, this case reiterates the importance of confirming patient eligibility. Due diligence must be performed to substantiate the patient receiving a vaccine dose, including an additional “third” or booster dose. Short of obtaining the patient’s medical record, utilizing PAAS’ COVID-19 Vaccine Self Attestation document, located on the PAAS Portal under Tools & Aids for PAAS Audit Assistance members, will help support a vaccine dose was appropriately given. For more information PAAS Audit Assistance members can refer to the October 2021 Newsline article, COVID-19 Vaccine Administration Audit Risk.

MedImpact is Turning Up the Heat on FWA Investigations

PAAS National® has recently received several FWA audit results requiring the pharmacy to submit additional, and arduous, supporting documentation. Pharmacies need to be aware of the audit risks for medications with high Average Wholesale Prices (AWP) and narrow FDA approved indications (e.g., Pennsaid®). Significant time and effort must be put forth by the pharmacy, prescriber and potentially the patient, to support these claims.

MedImpact FWA audit results are requesting numerous items to support the claims submitted by the pharmacy. Important to note, these results have included many claims that were never paid by the plan. Any claim submitted to a PBM can be requested for audit, even if rejected at point of sale. Clearly these FWA audits are not focusing solely on financial recoupment, but also suspicious conduct by the pharmacy (i.e., test claims). Keep the following in mind:

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  1. Prescriptions transferred from a pharmaceutical hub are under scrutiny. Claims for high AWP medications, with an origin code of 5, are easy claims for a PBM’s algorithm to flag. MedImpact results have come back to pharmacies requesting medical records to show proof of a valid patient/prescriber relationship and to support the necessity of the medication – often difficult to obtain. The audit results have also requested proof the patient authorized or requested these transferred prescriptions be filled prior to adjudication.
  2. Patient’s medication and pharmacy history are also being tracked by MedImpact during these audits. Prescription claims for patients starting on a high AWP formulation, versus potential lower cost therapies, are requiring a prescriber attestation with justification (again, not always easy to obtain). Pharmacies filling prescriptions for the first time for a patient, and only filling these high AWP medications, have been required to provide a written explanation of how these prescriptions were obtained.

With the current public health emergency, pharmacies must be diligent in verifying the legitimacy of telemedicine prescriptions, especially for high AWP medications. See the June 2019 PAAS Newsline article, Telemedicine: Questions to Consider from an Audit Perspective for more information.

Are You Violating PBM Return to Stock Policies? (including New PAAS Chart)

PAAS National® continues to see pharmacies losing money due to violating PBM Return to Stock policies. Each PBM sets a timeframe that unclaimed prescriptions must be reversed and returned to stock. Full recoupment of the claim can occur when a PBM discovers prescriptions are dispensed to patients outside this timeframe. Staying up to date on Return to Stock requirements is imperative. PAAS has a chart available on the PAAS Member Portal ( in our Tools & Aids section so you can stay up-to-date on these policies.

The strictest Return to Stock Policy is 10 calendar days. Pharmacies that currently have a policy for 14 days are running the risk of full claim recoupment from these specific PBMs.

Recoupments are preventable if pharmacies follow through on this very important task. PAAS Fraud, Waste & Abuse and HIPAA Compliance Program members have a customized policy in their manual.

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PAAS Tips:

  • Review and update your pharmacy policy for unclaimed prescriptions and make necessary changes to comply with strict PBM requirements, Section 4.1.1 Unclaimed Prescriptions of your PAAS FWA/HIPAA Compliance manual
    • Review and provide notice to staff of any updates/changes made to current policy.
    • Members may also refer to Appendix B of the manual for the Unclaimed Prescription Reversal Log. This is a helpful tool to assist pharmacies in completing this task.
    • Documenting when the task has been completed provides support that your pharmacy is following their FWA program.
  • Check with your software vendor on the ability to run reports to show prescriptions waiting to be picked up > 10 days
  • Software vendors may be able to set your point-of-sale system to deny the ability to sell past 10 days
  • Assign Return to Stock procedures to one person and allocate time to complete
  • See the June 2021 PAAS Newsline article, Would Your REMS Prescription Pass an Audit? for REMS dispensing and timeframe requirements
  • Be sure to review additional areas where waiting prescriptions are kept (e.g., refrigerator, special order shelf, or an overstock shelf)
  • Partial and LTC prescriptions also fall into these timeframe requirements

Not a PAAS Fraud, Waste & Abuse and HIPAA Compliance Program member? Contact PAAS today at (608) 873-1342 or and save $120 by combining services.

Billing Insulin & Related Supplies – Medicare Part B vs Part D

PAAS National® analysts frequently field questions about billing insulin and related supplies – this can be particularly confusing when the patient has Medicare coverage. Coverage of insulin and related supplies may depend on both the type of Medicare benefit and how the item is being used. Specifically, insulin vials and alcohol swabs could be covered under either Medicare Part B or Part D!

Remember that Medicare patients could have prescription and medical benefits that are separate or combined.

  • Separate: stand-alone medical benefit Fee-for-Service (FFS), also known as “Original Medicare” + stand-alone pharmacy benefit through a Part D Plan (PDP)
  • Combined:  medical and pharmacy benefit under one roof (sometimes called Medicare Part C) through Medicare Advantage (MAPD) Plan

Here is a chart to help you identify the correct payer depending on the type of Medicare benefit and the item in question.

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Pharmacy Medical Combined
Medicare Part D (PDP) Original FFS Medicare


Medicare Advantage


Insulin supplies
 Insulin pen Yes No Yes
 Insulin vial for self-administration Yes No Yes
 Insulin vial for pump1 No Yes Yes
 Insulin syringes Yes No Yes
 Alcohol Swabs for Part D drug2 Yes No Yes
 Alcohol Swabs for glucose testing No Yes Yes
Testing Supplies
 Test Strips No Yes Yes
 Lancets No Yes Yes

A few nuances to keep in mind:

  1. Generally, insulin for a pump is covered under Medicare Part B, unless the patient does not meet coverage criteria. See September 2020 PAAS Newsline article Billing Insulin for a Pump is Tricky, Especially for Medicare Patients for more details.
  2. Alcohol swabs are only covered under Part D when used for a Part D “drug” (like insulin or Humira®) according to Section 10.5 of the CMS Prescription Drug Benefit Manual Chapter 6. Additionally, PBMs are likely to audit for high AWP alcohol swabs or when used in excess (i.e., if patient is to use both “before and after” injection). See August 2019 PAAS Newsline article Why Would Anyone Audit Alcohol Swabs? for more details.

PAAS Tips:

  • If you are unsure about a patient’s Medicare coverage (PDP vs MAPD), then ask to see a copy of their card and look for “MAPD” or “Medicare Advantage” wording or call pharmacy help desk if needed
  • If a Medicare patient presents a prescription for insulin vials, clarify if self-administered or used in a pump
    • The instructions for use may make the route clear such that no clarifications are needed
    • The presence of insulin syringes on patient’s profile may also make the route apparent
  • If a Medicare patient presents a prescription for alcohol swabs, clarify what they are being used with

COVID-19 Vaccine Administration Audit Risk (including New PAAS Resource)

With additional doses of the COVID-19 vaccine being approved comes additional opportunities for COVID-19 audits, particularly in the realm of vaccine administration to Medicare beneficiaries at their homes and to the immunocompromised patient population.

At the beginning of June, Medicare began their initiative of paying approximately $75 per vaccine dose administered to patients who have difficulties leaving their homes or are considered “hard-to-reach”.  Effective August 24, 2021, Medicare broadened the locations in which patients can receive vaccine administration to include “communal space of a multi-unit or communal living arrangement.” Additionally, Medicare allowed for increased payment, allowing for the $75 payment amount up to a maximum of five vaccine administration services within a single group living location as long as less than 10 Medicare patients receive the COVID-19 vaccination dose on the same day at the same location. Take the following example of two Medicare beneficiaries in the same household which was laid out in CMS’ Medicare Payment for COVID-19 Vaccination Administration in the Home document, and serves as a great reference document to have on hand if providing at home COVID-19 vaccinations:

  • From June 8, 2021 to August 24, 2021: Medicare pays approximately $115 ($35 for the in-home vaccination rate plus 2 x $40 for each dose of the COVID-19 vaccine)
  • Effective August 24, 2021: Medicare pays approximately $150 (2 x $35 for the in-home vaccination rate plus 2 x $40 for each dose of the COVID-19 vaccine)

The audit risk lies in the need to document.

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To avoid risking an audit recoupment, there must be clear documentation to support their, “clinical status or barriers they face to getting the vaccine outside the home”. CMS provides the following situations:

  • They have a condition, due to an illness or injury, that restricts their ability to leave home without a supportive device or help from a paid or unpaid caregiver
  • They have a condition that makes them more susceptible to contracting a pandemic disease like COVID-19
  • The patient is hard-to-reach because they have a disability or face clinical, socioeconomic, or geographical barriers to getting a COVID-19 vaccine in settings other than their home. These patients face challenges that significantly reduce their ability to get vaccinated outside the home, such as challenges with transportation, communication, or caregiving

Secondarily, there could be audit risk tied to administering an additional dose of vaccine, again due to the need for proper documentation. Note that a third dose of the vaccine is separate and distinct from administering a booster dose of the vaccine. Refer to the table below for the specific details of each:

Additional (Third) Dose1 Booster Dose2
 Patient Demographic
  • Been receiving active cancer treatment for tumors or cancers of the blood
  • Received an organ transplant and are taking medicine to suppress the immune system
  • Received a stem cell transplant within the last 2 years or are taking medicine to suppress the immune system
  • Moderate or severe primary immunodeficiency (such as DiGeorge syndrome, Wiskott-Aldrich syndrome)
  • Advanced or untreated HIV infection
  • Active treatment with high-dose corticosteroids or other drugs that may suppress your immune system
  • Individuals 65 years of age or older
  • Individuals 18-64 years old at high risk of severe COVID-19
  • Individuals 18-64 years old whose frequent institutional or occupational exposure to SARS-CoV-2 puts them at high risk of serious complications of COVID-19 including severe COVID-19
 3rd Vaccine Dosing Interval At least 28 days after 2nd dose At least 6 months after 2nd dose
 Effective Start Date mRNA COVID-19 vaccine –

Approved 9/2/2021

Pfizer-BioNTech –

Approved 9/24/21

1 CDC COVID-19 Vaccines for Moderately to Severely Immunocompromised People

2 CDC Statement on ACIP Booster Recommendations

PAAS recommends having the patient attest to qualifying for an additional (third) dose, or booster dose, of the mRNA COVID-19 vaccine, although we do not believe knowing the patient’s exact diagnosis or condition is necessary. In a meeting between the CDC and NCPDP, it was stated that, “Providers should be responsible to receive attestation from patients regarding appropriate timelines”. Included in October’s Newsline is a new resource: COVID-19 Vaccine Additional (Third) Dose and Booster Dose Self-Attestation of Eligibility. You can find this resource under our Tools & Aids section of the PAAS Member Portal ( Pharmacies can use this attestation for patients to fill out at the time of vaccine administration. Consider filing it with your placeholder prescription for easy retrieval.

Getting Help with an Audit

Oh no! You just received an audit, now what? First step is to get your audit notice to PAAS National® as soon as you receive them.

Pre-audit assistance steps:

  1. Call (608) 873-1342 to get a case step-up for your incoming audit notice
  2. Send in your audit, one of three ways and please reference the case number upon sending in:
    • Email the audit notice to
    • Fax to (608) 873-4009
    • Upload an audit on the PAAS Member Portal under “Access Services” in the left hand navigation
  3. Upon receiving your notice, a PAAS Analyst will reach out to you within 1-2 business days to guide you on next steps and documentation collection.

Post-audit/appeal assistance:

  1. Get your audit results to PAAS as soon as you receive them via email or fax (608) 873-4009, please reference the case number upon sending in. Note: If you don’t have a case set-up with us from pre-audit assistance, please call (608) 873-1342 to start a case.
  2. Upon receiving the results, a PAAS Analyst will review your results and provide appeal guidance as soon as possible.


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  • Send all pages of audit notice to PAAS before you start document collection
  • All audits have deadlines, time is of an essence for getting PAAS the notice and/or appeals. The more time we have the better.
  • When additional information is requested, organize documents in order as per the audit notice
  • If you have multiple pages, numbering the pages has provided many benefits including:
    1. Better organization
    2. Ensuring nothing is missing
    3. Making phone calls with PAAS team or PBM auditor more efficient