Flu Shot Season – Are You Prepared?

Flu shot season is just around the corner and PAAS National® wants to make sure you reduce your risk of audit recoupments. As busy as the flu season can be, it is important to follow the best practices and PAAS tips below to ensure you have all documentation in place.

What you will need for an audit:

Become an audit assistance member today to continue reading this article. As a member, you’ll have access to hundreds of articles and receive our monthly proactive newsletter!

  1. Authority to administer
    • A signed order from an authorized prescriber (may include pharmacists, based on state regulations) or,
    • A signed protocol or Collaborative Practice Agreement (CPA) that is up to date and includes specific vaccination(s) to be administered
      • The amended Public Readiness and Emergency Preparedness (PREP Act) authorizes pharmacists to continue to administer COVID-19 and seasonal influenza vaccines to individuals aged 3 and above and order and administer COVID-19 tests in accordance with an FDA license, approval, or authorization through December 31, 2024
  2. Signed prescription or placeholder prescription (when using a protocol or CPA) that contains all prescription elements required by state and federal regulation (a VAR may suffice)
  3. Vaccine Information Statement (VIS)
    • Required to be given to patient prior to each administration
    • Be sure you have the most current VIS forms
  4. Screening Checklist
    • Not requested by PBMs; however, should be retained for your records
  5. Vaccination Administration Record (VAR)
    • Date of administration
    • Name and manufacturer of vaccine administered
    • Lot and Expiration Date of vaccine given
    • Site of administration (i.e., right arm)
    • Signature or initials and title of person administering
    • What VIS form was given
      • Date printed on the VIS
      • Date the VIS was given to the patient or parent/guardian
    • For pharmacists with independent prescriptive authority, a VAR that contains all the elements of a prescription

VAR and VIS forms, and information regarding what the CDC requires for health care providers to record, can be found on the CDC website.

PAAS Tips:

  • Check dates and vaccine types on your protocols to ensure they are up to date
  • Have current VIS forms printed for each vaccine you administer
  • Have VAR forms printed and educate all staff on how to complete the forms
  • All vaccines should be submitted using a days’ supply of “1” per NCPDP recommendations
  • All vaccines administered via protocol should be submitted with origin code of “5” (pharmacy created) per NCPDP recommendations
  • Be sure the correct metric quantity is billed
  • Keep vaccine documentation stored in a system that makes access easy in case of an audit
  • PAAS has seen pharmacies flagged for billing claims outside regular pharmacy hours – consider billing for vaccine claims during regular business hours only
  • When billing for vaccine clinics, DO NOT bill prior to the vaccine being administered
    • You may submit claims after the date of service, but the date of administration must be correct on the claim
Jennifer Ottman, CPhT