Insufficient/Missing Clinical Notes Yield Audit Recoupments

PAAS National® analysts are seeing more prescriptions flagged for recoupment when insufficient or missing information is not verified with a valid clinical note. Nothing is more frustrating than having the validity of the clinical notes questioned by a PBM auditor because they are incomplete, but that is exactly what is happening!

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In particular, OptumRx and Humana are creating headaches for pharmacies, requiring prescribers to validate the clinical note to avoid recoupment.

Inevitably, pharmacies will receive prescriptions that contain missing elements or need clarification. To avoid a potential recoupment, clear documentation is essential.

PAAS recommends four elements for clinical notes:

  1. Date (and preferably time) of the call/conversation
  2. Name and title of who you spoke with
  3. Specific details about the clarification
  4. Initials or name of the pharmacy employee making the clarification

PAAS Tips:

  • Instruct staff and have a policy on how clinical notes will be documented
  • Some pharmacies have created customized ink stamps to facilitate and promote this documentation process for staff
  • Check with your software vendor on how to utilize the electronic notes field
  • If making handwritten clinical notes, ensure you rescan the prescription into your software
  • Any notations made on previous prescriptions that are still valid should be carried forward to the new prescription
  • If the patient instructions are clarified, ensure the patient label is updated prior to dispensing to reflect the new directions
  • Upon an audit, be sure all clinical notations are clearly visible to the auditor
  • See the June 2023 Newsline article, Carry Clinical Notes Forward for Audit Coverage
  • See the August 2023 Newsline article, Electronic Clinical Notes: Are They Required?
Jennifer Ottman, CPhT