How to Submit Your Audit Documents for an Effective Review
PAAS National® analysts continue to see an increasing amount of PBM audits demanding large audit volumes of documents for reviews. Our goal is to help pharmacies respond accurately and efficiently as you submit documentation.
PAAS analysts review your documents as if we are performing remote pharmacist verification, so it is helpful if we can see both the prescription AND the billing information at the same time.
Upon receiving an audit notice, send it to PAAS. This allows for the analyst on your case to provide guidance from the very beginning of the audit process, which can result in you saving time gathering less paperwork. Additionally, it allows the analyst to provide guidance on what to look for as documents are pulled, such as any electronic clinical notes that need to be added to the hardcopy. This can result in a more efficient, and seamless, pre-audit consult after documents have been reviewed by your analyst, ensuring an effective review for your audit.
General
- Organize documents in the same order as listed on audit letter
- If prescriptions/signature logs are requested in two separate “lists”, then separate them in your response (rather than co-mingled)
- Include page numbers at the bottom of each page in sequence to ensure no pages are missing and to allow for easy reference if needing to refer an auditor to a contested aspect of your audit.
Prescription Hardcopies
- Only produce one copy per unique Rx #
- Only include back of prescription if it has information, otherwise write “back is blank” on the face of the
hardcopy
- Include “fill sticker/back slap/backtag” on the front side of the prescription, in the same orientation
- Make sure clinical notes are visible to support claim as billed
- Include Patient label (if requested)
- If any DUR, SCC, DAW or Diagnosis code was submitted, then documentation should include both the code used and a clinical note to justify its use
- Make sure to document on the hard copy if the prescription is a transfer or phoned in order
Signature Log
- Only provide for specific date(s) of service when requested
- Must include at least 3 elements: Rx number, date of dispensing, signature or “COVID-19” (where applicable), some PBM’s require the fill date or refill #
- Omit PHI for any Rx not subject to audit and be sure to point out the Rx number in question
Copay Collection
- Only provide for specific date(s) of service when requested
- Point-of-Sale transaction receipts with Rx number, copay amount, and method of payment
PAAS Tips:
- Getting help with an audit, you can submit via email, fax, or upload. If uploading electronic file(s) to Member Portal, submit as one aggregated file.
- See PAAS’ Newsline article:
- What Should Be Included on Your Backtag? for recommendations on how “fill stickers/back slaps/backtags” should be formatted to include written date, day supply, DAW, origin code
- Diagnosis Restricted? Documentation Required! for assistance on diagnosis restricted documentation
- For DAW code utilization see Are You Utilizing DAW Codes Correctly? Updated Tool Available!
- Proper Clinical Notes are key to a successful audit, check out Carry Clinical Notes Forward for Audit Coverage
- Additional documentation may be needed in select circumstances as shown below:
- If you do not have a Point-of-Sale system (or for investigational audits), then you may need to provide evidence of financial transaction including (a) credit card receipts, (b) copies of cancelled checks and (c) bank deposit slips for cash
- If claim was billed to a secondary payer or an eVoucher was used, then include screenshot of secondary claim to identify BIN, PCN, authorization #, amount paid and remaining patient out of pocket
- If copay charged to A/R account, then provide ledger showing charges and payments
- Print and share these resources with other staff that are preparing and submitting audits:
- How to Submit Your Audit Documents for an Effective Review - October 13, 2024
- Caremark® Continues to Recover Payments for Unapproved Coupons - September 21, 2024
- Are PBM Regulations Being Enforced by Your State? Let Your Voice Be Heard! - August 28, 2024