Invoice Audits Are on the Rise – Are You Prepared for Success?

Most pharmacies have grown accustomed to desk audits and providing copies of prescriptions, signature logs, and even copay collection records to PBMs upon request. Additionally, many pharmacies can recount their most recent experience with an onsite auditor visiting their pharmacy and the numerous questions related to operations, policies & procedures, and credentialing. However, not as many pharmacies have experienced an invoice audit – the stakes are higher and honest mistakes can lead to very expensive lessons in the process.

PAAS National® analysts have helped our members navigate countless invoice audits. Our analyst team is here to assist you through the audit process from start to finish and that includes getting things done correctly long before the audit ever comes your way. Follow the tips below to have the most success.

PAAS Tips:

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  • Carefully evaluate your wholesalers/suppliers to ensure they are legitimate
    • NABP Accredited Drug Distributors can be found here
    • Wholesalers licensed in your state can be found here
    • Remember that OTC diabetic test strip manufacturers only sell their products to “authorized distributors” – see June 2023 Newsline article, LifeScan Extortion – Diabetic Test Strip “Authorized Distributors” for links to manufacturer websites
  • Limit purchases from other pharmacies to the minimum necessary
    • Drug Supply Chain Security Act (DSCSA) pedigree information is required unless purchase is (1) intra-company or (2) to fulfill a specific patient need
    • Full transaction details are required for audit purposes – see December 2022 Newsline article, Pharmacy to Pharmacy Inventory Transfers – Buyer Beware! for necessary documentation including selling pharmacy information and method of payment
  • Ensure pharmacy staff are billing the correct quantity based on NCPDP billing standards – when in doubt, call PAAS for help
  • Every claim billed must have NDCs that match the physical product being dispensed
    • No exceptions, all 11 digits matter
    • Includes all compound ingredients
    • PAAS recommends using barcode scanner to confirm NDC accuracy in pharmacy workflow
  • Confirm the pharmacy is appropriately reversing claims that are not dispensed

Eric Hartkopf, PharmD