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!
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:
- Date (and preferably time) of the call/conversation
- Name and title of who you spoke with
- Specific details about the clarification
- Initials or name of the pharmacy employee making the clarification
- 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?
- DMEPOS Updated Refill Request and Affirmative Response Requirements - February 11, 2024
- 2024 Update: CMS Mandatory E-Prescribing Requirements for Controlled Substances – Final Rule - January 18, 2024
- PBM Prescription Validation Requests Rose 123% in 2023 – What You Need to Know - January 12, 2024