How Can I Avoid Humana Audits for Deceased Patients?

Humana has recently sent out audits to pharmacies with a subject line stating Review of claim(s) billed after member’s deceased date. This review is taking place, sometimes more than a year after the date of service, because some Medicare Part D claims were paid after a beneficiary passed away. Why would Humana wait so long to review these claims, and why did they not stop them at point of sale? Unfortunately, there is usually significant lag time from when a patient passes away to when this information is reported to the Social Security Administration, and then to CMS and Plan Sponsors.

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To combat these recoupments, pharmacies are allowed to submit documentation to demonstrate the claim was billed appropriately. If the date of service is within 14 days from the deceased date for retail claims, or within 32 days from the deceased date for long-term care claims, a pharmacy can send signed proof of delivery or a signature log showing someone received the medication on the patient’s behalf. If the deceased date is incorrect on Humana’s records, an obituary showing the correct date of death can be sent.

There are some things you can do to help avoid these situations to begin with.

PAAS Tips:

Always obtain patient consent prior to delivery of any auto-refilled or synchronized medications
This is a Medicare requirement to prevent waste
Do not leave the medication at the door without getting a signature from the patient or caregiver
Use extra caution with controlled substances, especially if being requested by a different family member or if only controlled substances are being ordered
See the October 2021 article, Self-Audit Series #9: Controlled Substance Prescriptions
For additional tips, please see the January 2022 articles:
- Would Your Delivery/Signature Logs PAAS an Audit?
- Mailing Prescriptions: How Do You Prove Patient Receipt?

Author
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Jenevra Azzopardi, CPhT

Analyst at PAAS National^®

I grew up in a family of nurses and other medical professionals but was never interested in the clinic setting. I was drawn to pharmacy because I like to help people and could easily use the knowledge I grew up with to do so. It was a great fit.  

I have a Bachelor of Arts in Communications from the University of Wisconsin – Madison. Prior to joining PAAS in 2017, I worked for Walgreens for 19 years.

As an Analyst at PAAS, I really enjoy being able to help independent pharmacies succeed. I have always been a fan of the underdog and am excited to be able to give you the tools you need to take on the giants of the PBM industry.

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