Required: Proof of Patient Copay Collection

Other things to consider when proof of copay collection is required:

Credit card receipts should include:

• The last four digits of the credit card number
• The transaction authorization number
• The merchant ID number

Payment by check may require copies of cancelled checks, front and back.

Payment by cash may require proof of cash bank deposits being made during the timeframe under audit.

Reduction of copay due to a secondary payer (coupon or secondary insurer) may also require proof including:

• A print screen showing adjudication to the secondary insurer
• Secondary payer plan information like the BIN, PCN, Patient ID, and group number
• Any eVoucher data applied by the switch
• Amount paid and any remaining out of pocket amount

If using a house charge account, you should be able to produce the following:

• Policy and Procedure for collection of monies due on the account
• Documented attempts to collect payment in the form of dated invoices sent to the patient and logged phone calls attempting to collect
• Itemized Accounts Receivable report showing payment received, tying the payment back to the prescription number, and any outstanding balance remaining

If waiving a copay due to financial hardship, you will need objective evidence of that hardship, like an application, tax returns, and a formal written Policy and Procedure. It cannot be advertised or promoted, nor funded, in whole or in part, by a third party. It also must meet all requirements and restrictions of applicable law.

Non-routine, unadvertised waivers of copayments based on individualized determinations of financial need for patients with Medicaid may be acceptable without a financial hardship Policy and Procedure.

PAAS Tips:

• Use an integrated POS system to reduce risk of recoupment
• Copays should be collected at the time of sale as a best practice
• House charge accounts require a strong Policy and Procedure for collection
• Ensure good cash handling policies
  • Make bank deposits at regular intervals
  • Avoid taking money directly from the register for business expenses
  • Balance the register at the end of the day
• See the following Newsline articles for more information:
  • Proof of Copay Collection – Secondary Payers Hidden in Plain Sight (March 2023)
  • Staying Compliant with House Charge Accounts (January 2024)
  • Best Practices for Financial Hardship Waivers (December 2023)
  • Copays for Pharmacy Staff and Family (June 2022)
• PAAS Fraud, Waste & Abuse and HIPAA Compliance members should review section 1.5 – Copay Collection in your Policy and Procedure Manual